Michael M. Dew - Page 3

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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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