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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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