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the notice of deficiency was invalid because respondent failed to
mail it to petitioners’ last known address. Petitioners resided
at 6100 Edinger Avenue, #634, Huntington Beach, California 92647
(the Edinger Avenue address), at the time they filed their
petition.
Respondent determined a deficiency in petitioners’ 1992
Federal income tax in the amount of $12,959 and an accuracy-
related penalty under section 6662(a) in the amount of $2,592.
On July 16, 1996, respondent mailed duplicate copies of the
notice of deficiency by certified mail to 11815 Blake Road,
Wilton, California 95693-8542 (the Blake Road address), and to
17931 Fern Point Circle, Huntington Beach, California 92647 (the
Fern Point Circle address). The petition was filed herein on
October 7, 1998, more than 2 years after the mailing of the
notice of deficiency. Respondent alleges that the notice mailed
to the Fern Point Circle address was returned undeliverable, but
that the one mailed to the Blake Road address was not.
During the examination of petitioners’ 1992 Federal income
tax return, petitioners signed and submitted to the Internal
Revenue Service a Form 2848, Power of Attorney and Declaration of
Representative, naming James F. Christensen (Mr. Christensen),
3151 Airway Avenue, Suite B1, Costa Mesa, California 92626 (the
Airway Avenue address), as their representative. The Form 2848
was dated by petitioners on November 22, 1995, and by Mr.
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