Frank Blazic - Page 7




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            claimed by petitioner.6                                                                    
                  In this case, the San Leandro address is the address listed                          
            on the return filed most recently before the issuance of the                               
            notice.  The San Leandro address was also the address listed for                           
            petitioner in respondent’s computerized database on dates shortly                          



                  6 There are other inconsistencies between petitioner’s                               
            testimony and statements contained in documents filed prior to                             
            the hearing.  In the petition, petitioner alleges that he did not                          
            receive the notice and “had no knowledge of the mailing of such                            
            until several months after the purported mailing”.  (Emphasis                              
            added.)  In the declaration referred to above he states that he                            
            was “wholly unaware of any IRS audit for 1987 and any deficiency                           
            determination until 1997/1998 when * * * [he] was contacted by                             
            IRS Collection”.  At the hearing, he testified on direct                                   
            examination as follows:                                                                    
                  Q.  When did you first find out that you – that the                                  
                  IRS had made a tax assessment against you?                                           
                  A.  I believe it was in ’97, or 1998 – probably ’97.                                 
                  Q.  Would you state how you discovered this fact?                                    
                  A.  The Franchise Tax Board sent a levy on my wages at                               
                  Eckhoff Accountancy Corporation.                                                     
                  Q.  And what did you do after you found out about that                               
                  levy?                                                                                
                  A.  I then contacted – after speaking with the Franchise                             
                  Tax Board, they indicated to me to contact the                                       
                  Internal Revenue Service, which I did.                                               
                                         *   *   *   *   *   *   *                                    
                  Q.  And when was the first time you discovered that                                  
                  the IRS did, in fact, send you a 90-day letter?                                      
                  A.  I believe I already answered that question.  I                                   
                  think it was ’97 or ’98.  Somewhere in there.                                        






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