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Christensen on November 30, 1995. (We note that the address of
petitioners shown on the Form 2848 was the Fern Point Circle
address). On October 16, 1996, respondent sent a copy of the
notice of deficiency for petitioners’ 1992 taxable year to Mr.
Christensen by regular mail. Mr. Christensen received the notice
of deficiency but did not advise petitioners of the receipt
because he believed that petitioners’ 1992 return was being
handled by a San Francisco law firm. Mr. Christensen filed the
copy of the notice of deficiency in his records.
Page 2 of the Form 2848, under the heading “Notices and
Communications”, states: “Notices and other written
communications will be sent to the first representative listed on
line 2.” The form further provides two blocks to be checked to
vary the statement, but neither block was checked.
By letter dated July 13, 1995, petitioners advised Revenue
Agent Curtis Lawrence that they had moved to northern California
in August 1994. The letter continues: “I request any inquiry
required in regards to Maranto Enterprises be forwarded to a
location closier [sic] to my home.” The letter reflects the
Blake Road address. Petitioners filed their 1994 Federal income
tax return in October of 1995. That return reflects the Blake
Road address.
This Court’s jurisdiction to redetermine a deficiency
depends upon the timely issuance of a valid notice of deficiency
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