Keith K. Stroupe - Page 7

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          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.             






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