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return, filed March 15, 1991.2 The San Leandro address is also
shown as petitioner’s address on his 1990 Federal income tax
return, filed October 18, 1991, which is the most recently filed
return before the notice was issued.
The examination of petitioner’s 1987 return began in April
1993. During the course of the examination, several letters were
sent to petitioner at the San Leandro address. Although letters
sent by respondent to petitioner at another address were returned
as undeliverable during the examination,3 nothing in the record
suggests that any of the letters addressed to petitioner at the
San Leandro address were returned to the examining agent. As
best as can be determined from the record, petitioner never
2 The notice was also sent to petitioner at an address in
Grass Valley, California. Petitioner had provided this address
to an employer, and that address was on a Form W-2 issued to
petitioner. However, the notice mailed to this address was
returned to respondent by the U.S. Postal Service. Respondent
agrees that the Grass Valley address was not petitioner’s last
known address.
3 In August 1993, the examining agent sent two letters, one
by certified mail, to petitioner at an address in Auburn,
California. Both letters were stamped as undeliverable and
returned. Apparently, the Auburn address was listed on documents
filed by, or on behalf of, petitioner in a bankruptcy proceeding
initiated in May 1990 and concluded in March 1994. The Auburn
address was used on respondent’s Proof of Claim for Internal
Revenue Taxes submitted in that bankruptcy proceeding on Dec. 23,
1991. On Dec. 7, 1993, a Notice of Intent to Enter Final Decree
and Close Chapter 11 Case was filed in the bankruptcy proceeding.
The Auburn address was listed as petitioner’s address in that
notice.
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