- 6 - formatting and style of the message contained therein is likewise different from her previous letters. Petitioner further alleges that she called Ms. Murdock’s office in January 1999 and was told that Ms. Murdock was no longer handling her case. Petitioner claims that when she spoke to the secretary who answered the phone, she identified herself with her Social Security number and the Adele Street address. Lastly, petitioner contends that since she received her tax booklet in early January at the Adele Street address, respondent knew of this address before the notices of deficiency were issued in February. Respondent contends that the notices of deficiency were sent to petitioner’s last known address, and petitioner failed to petition the Court within the statutory period. Respondent argues that petitioner’s October 1998 and November 1998 letters did not provide “clear and concise” notice of an address change. Testimony of Mitchell Farah During the first hearing on this matter, the Court questioned how respondent was able to send the tax booklet for 1998 to petitioner’s Adele Street address. Respondent subsequently moved to reopen the record to answer this concern (which motion was granted), and a second hearing was held. Respondent called Mitchell Farah (Mr. Farah) as a witness. Mr. Farah is the manager of the mailouts and composition section ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011