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forwarded by the U.S. Postal Service to petitioner at 578 Fox Paw
Trail, Annapolis, MD 21401. In any event, on March 9, 1998, the
envelope was returned to respondent undelivered and marked
"Unclaimed". The notice of deficiency mailed in the care of
Wallace and Company was not returned to respondent.
On May 11, 1998, a representative of Wallace and Company
filed a petition with the Court on petitioner's behalf contesting
petitioner's tax liability for 1993 and 1994.3 The first page of
the notice of deficiency attached to the petition--the notice of
deficiency for 1993 that respondent mailed to petitioner in care
of Wallace and Company--included a handwritten notation listing
the 1994 year and a deficiency of $1,969.
The petition, which is dated April 29, 1998, arrived at the
Court in an envelope bearing a private postage meter postmark
date of April 29, 1998, and a U.S. Postal Service postmark date
of May 8, 1998.
On May 18, 1998, after the petition in this case was filed,
respondent mailed a notice of deficiency to petitioner
determining a deficiency of $1,969 in his Federal income tax for
1994. Respondent did not issue any notice of deficiency to
petitioner for 1994 before the petition in this case was filed.
On August 17, 1998, petitioner filed a petition with the Court,
assigned docket No. 14211-98S, contesting the notice of
deficiency for 1994.
3 At the time the petition was filed, it appears that
petitioner resided in Easton, Md.
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