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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.
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