Audrey Carlisle - Page 5




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          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, the               






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