Ronald Thomas - Page 8

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          Further, the notice of deficiency was returned to respondent                
          marked "Unclaimed" (as opposed to "Addressee Unknown",                      
          "Insufficient Address" or "Unable to Forward"), indicating that             
          certified mail notices were left at the Lightning View address,             
          yet the notice of deficiency was not claimed.  See, e.g., Erhard            
          v. Commissioner, T.C. Memo. 1994-344, affd. 87 F.3d 273 (9th Cir.           
          1996).                                                                      
               Petitioner contends that he provided oral notice to                    
          respondent's revenue officers in the fall of 1983 that he had               
          changed his address to the Rogers Avenue address.  However, the             
          revenue officers who were in contact with the Thomases during               
          this period could not recall being informed of, or ever visiting,           
          the Rogers Avenue address.  The record does show that                       
          respondent's Collection Branch in Philadelphia was aware that               
          petitioner might be contacted at the Rogers Avenue address--the             
          Collection Branch used that address in mailing the Form 4901 to             
          petitioner on December 30, 1983.  The revenue officers from the             
          Collection Branch in Philadelphia were not involved with the                
          examination of petitioner's individual income tax liability for             
          1978.  They were concerned with efforts to collect Delafield's              
          unpaid Federal employment taxes for 1980 and 1981 and/or the                
          imposition of the 100-percent responsible person penalty against            
          the Thomases with respect to those taxes, whereas the deficiency            
          notice for Federal income tax for 1978 was issued by the District           





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