- 7 - does not enter any address information received in this manner on any of his databases; and (4) if no remittance accompanies the request, the request is filed and subsequently destroyed by respondent 1 year after the end of the processing year. See Internal Revenue Manual sec. 512(12)(2)(g); Internal Revenue Manual Handbook, sec. 1(15)59.26 at par. 68. Except for the requests for extension, respondent did not receive any correspondence from petitioner prior to the mailing of the notice of deficiency. Further, prior to the mailing of the notice of deficiency, no division of the Internal Revenue Service had ever corresponded with petitioner at the Kansas address. Respondent received two Forms 1099-MISC with respect to petitioner from a third-party employer bearing the Kansas Address. Respondent's records reflect that these information returns were received by respondent in 1995 and were issued in respect of the taxable year 1994. About 3 years after the notice of deficiency was mailed, respondent mailed a copy of a notice of Federal tax lien to petitioner in September 1997, at the Kansas Address. Petitioner mailed his petition for redetermination to the Court in an envelope bearing a private postmeter postmark date of October 31, 1997. The petition was filed by the Court on November 3, 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011