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additions to, petitioner's Federal income taxes for the taxable
years 1988 and 1989 as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1988 $39,748 $9,937 $2,543
1989 4,120 1,030 277
Respondent mailed a copy of the notice of deficiency to
three addresses, namely, the Colorado Springs Address, the
Nathrop Address, and a third address, 4910 Granby Circle,
Colorado Springs, CO 80919 (the Second Colorado Springs
Address). Respondent had not previously mailed any
correspondence to petitioner at the Second Colorado Springs
Address, but had obtained such address using Form 3242 (Request
for Information from Employer). Respondent received this form
back from the employer in February 1994. The Second Colorado
Springs Address was the address last used by petitioner with this
employer.
Each of the envelopes bearing a copy of the notice of
deficiency was returned to respondent by the Postal Service. The
following notations appeared on the various envelopes: For the
Colorado Springs Address, "addressee not known" and "does not
live here anymore"; for the Nathrop Address, "attempted, not
known; no such number; insufficient address"; and for the Second
Colorado Springs Address, "addressee not known".
For each of the years 1987 through 1994, petitioner filed
Forms 4868 (Application for Automatic Extension of Time to File
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Last modified: May 25, 2011