- 4 - returned to respondent marked "Unclaimed". Shirley Thomas was residing at the Lightning View address throughout the period in question. The record indicates that the notice of deficiency was mailed to the Lightning View address on the basis of information contained in the Thomases' administrative file and that respondent did not conduct a computer search for petitioner's address before mailing the notice of deficiency. The record does not reflect whether respondent made any further efforts to deliver the notice of deficiency to the Thomases immediately after the original notice was returned undelivered.2 Between 1982 and 1984, the Thomases were contacted by various revenue officers concerning the collection of Delafield's unpaid Federal employment taxes and the possible imposition of the 100-percent penalty against the Thomases with respect to those taxes. Sec. 6672. Revenue Officer James Land met petitioner during a field visit to Delafield's McDonald's restaurant in Baltimore.3 In July 1982, Revenue Officer Grace Jaecksch prepared a Form 4180, Report of Interview Held With Persons Relative to Recommendation of 100-Percent Penalty Assessments, based upon an interview with Shirley Thomas. On April 19, 1984, Revenue Officer Carla Mims-Dixon met with Mrs. 2 The Commissioner destroyed the Thomases' administrative file in the normal course of business. 3 The record does not reflect the date of this visit.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011