Laura A. Loveland Espinosa - Page 7




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          that a form letter previously sent to him had been returned                 
          showing his address as “1278 Glenneyre #15”, “Laguna Beach, Ca.             
          92651”.  Subsequent to mailing the deficiency notices, the IRS              
          sent to the Laguna Beach postmaster a document on May 8, 1989,              
          requesting current address information for Mr. Espinosa and                 
          received in response “375 Broadway #214”, “Laguna Beach, Ca.                
          92651”.  During this period, Mr. Espinosa maintained a post                 
          office box at the Glenneyre address and resided at the Broadway             
          address.  IRS records do not indicate that the deficiency notices           
          were re-sent to either of these locations.  The taxes set forth             
          in the notices were assessed against Mr. Espinosa on November 27,           
          1989, and lien notices were thereafter recorded in three southern           
          California counties.                                                        
               In late 1990, an IRS agent contacted Mr. Espinosa at Lidak,            
          and the two later met to discuss his tax liabilities.  As a                 
          result of this meeting, Mr. Espinosa began making payments to the           
          IRS on January 3, 1991.  The payments ceased at the end of 1991,            
          when his termination from Lidak left him with no source of                  
          income.  The only further payment was made on July 15, 1993.  The           
          payments totaled between $93,000 and $94,000.  Respondent applied           
          all payments to Mr. Espinosa’s 1980 liability for income tax,               
          additions to tax, and interest, as determined by respondent in              
          the 1989 deficiency notices.                                                








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