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redetermination of their tax liability for 1978. At the time,
the Thomases continued to reside together at the Lightning View
address. On November 30, 1983, the Court dismissed the Thomases'
petition on the ground that respondent had not issued a notice of
deficiency to the Thomases for 1978.
During the fall of 1983, petitioner and Shirley Thomas were
experiencing marital difficulties and decided to separate. To
reduce the impact on his children, petitioner left the Lightning
View address. By December 1983, petitioner had moved into an
apartment at 4016�, North Rogers Avenue, Baltimore, Maryland
21207 (the Rogers Avenue address).
On December 30, 1983, the Chief of the Collection Branch
assigned to the Internal Revenue Service Center in Philadelphia,
Pennsylvania, sent a Form 4901, Request for Information About Tax
Form, to petitioner at the Rogers Avenue address stating that
respondent had no record of receiving his 1982 tax return. The
record does not clearly reflect how the Collection Branch became
aware of petitioner's Rogers Avenue address.
On January 30, 1984, the Internal Revenue Service District
Director in Baltimore, Maryland, mailed a joint notice of
deficiency to the Thomases determining a deficiency of $36,401.86
in their Federal income tax for 1978 and an addition to tax under
section 6651(a) in the amount of $9,592.40. The notice, which
was mailed by certified mail to the Lightning View address, was
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