- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011