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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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