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the letterhead. There is no statement in the letter indicating a
change of address, and respondent did not make such a change.
According to notes taken by Ms. Murdock, she attempted to
call petitioner three times in December 1998 and twice in January
1999. The number she called was that of petitioner’s brother.
On January 8, 1999, Ms. Murdock left a message on the answering
machine4 for petitioner. In her notes Ms. Murdock wrote: “Left
message if she does not contact us by 1-12 we’ll send 90 day
letter.”
By letter dated January 20, 1999, the IRS sent petitioner a
form letter to the Crescent Avenue address thanking her for her
correspondence dated November 12, 1998. The letter stated that
the IRS had not yet reviewed the information she sent but would
contact her within 60 days to let her know what action would be
taken. The letter was signed by the Chief of the Fresno Service
Center Examination Branch.
In early January 1999,5 petitioner received her 1998 Form
1040A instructions booklet (tax booklet). This tax booklet was
mailed to the Adele Street address.
On February 3, 1999, respondent mailed 1995 and 1996 notices
of deficiency to the Oak Street address by certified mail. These
4 Ms. Murdock testified that petitioner identified herself
on the outgoing answering machine greeting.
5 Petitioner believes that she received her tax booklet
between Jan. 2 and 7, 1999.
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Last modified: May 25, 2011