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the route 208 address, Williams would deliver them to
petitioners.
Williams does not remember the envelope containing the
statutory notice. She is unable to recall whether she delivered
this particular piece of mail.
On November 10, 1992, the envelope containing the statutory
notice was returned, unopened, to respondent. The envelope bore
a "Returned to Sender" stampmark in red ink, and the "REASON
CHECKED" for return was "Unclaimed". Additionally, the words
"Return unclaimed" had been handwritten, by Walker, at the top of
the envelope. The envelope also listed three dates. Two of
these dates purported to be the dates on which Williams had
delivered to petitioners notices informing them that they needed
to come to the Post Office to claim the envelope. The last date
indicates the date on which the envelope was returned to
respondent. The date of the "1st Notice" was listed as "9-24",
presumably a reference to September 24, 1992. This date preceded
the date of the enclosed notice of deficiency by more than 2
weeks. The date on the "2nd Notice" was listed as "10-16", and
the date of return was listed as "10-19".
Respondent made no further effort to contact petitioners
concerning the tax deficiencies.
One of petitioners' accountants and tax advisers, Noreen
Masztal, C.P.A., testified that in mid-1992 she warned
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Last modified: May 25, 2011