- 5 - notices were returned to respondent in late February as unclaimed. On March 13, 1999, respondent received petitioner’s 1998 income tax return, which reflected the Adele Street address. At that time, respondent updated his database to show the Adele Street address for petitioner. In April 1999, petitioner’s case was sent back to Ms. Murdock. While looking through petitioner’s file, Ms. Murdock noticed the Adele Street address on the letterhead of petitioner’s prior letters. Ms. Murdock checked the database and noticed that petitioner’s address had been updated. On April 23, 1999, Ms. Murdock caused a letter to be sent to petitioner at the Adele Street address, transmitting copies of the notices of deficiency and explaining that the 90-day statutory period for filing a petition with the Tax Court was not extended. The 90- day period within which to timely file a petition with this Court expired May 4, 1999. Petitioner filed her petition on July 20, 1999. Petitioner alleges that on January 11, 1999, she sent another letter to respondent stating a change of address to the Adele Street address. Respondent claims that letter was never received. Petitioner’s copy of that purported letter appears to have been written on stationery or notepaper which is different from all her other correspondence in the file. Moreover, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011