- 4 - names. The copy of the notice placed in evidence by respondent only lists Mr. Wheeler's name. Respondent asserts that Mrs. Wheeler's name was not listed on the notice mailed to the El Jer address and that her name was added sometime after the notice was mailed. Mrs. Wheeler's name as it appears on the copy of the notice presented by petitioners does appear to have been added after the initial text was drafted. Mrs. Wheeler's name on petitioners' copy is typed in a different font from the rest of the text. Petitioners do not contest respondent's assertion that Mrs. Wheeler's name apparently was added after the notice of deficiency had been prepared. Instead, petitioners claim that Mrs. Wheeler's name was added by respondent before the notice was mailed. Based upon this record, we find that the notice was not issued to Mrs. Wheeler. Michael Meyering (Mr. Meyering), an agent in respondent's examination review staff, was assigned to work on a case regarding Mr. Wheeler for the years 1992 through 1996. Mr. Meyering was not assigned to work on a case regarding Mrs. Wheeler. Upon completion of the audit, Mr. Meyering prepared duplicate statutory notices of deficiency in the name of Mr. Wheeler. Mr. Meyering did not prepare a joint notice for Mr. and Mrs. Wheeler. A certified mailing list introduced by respondent verifies that duplicate originals of the notice were issued to Mr. Wheeler. The certified mailing list does notPage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011