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the stipulated exhibits are incorporated herein by this
reference.
When the petition was filed in the instant case, petitioners
resided in Henderson, Nevada.
On October 22, 1997, respondent issued a notice of
deficiency to petitioners for 1995. This notice of deficiency
was sent by certified mail to petitioners at “25521 La Mirada,
Laguna Hills, Ca. 92653-5316217.” This address is hereinafter
sometimes referred to as the 12-digit ZIP Code address.
On October 22, 1997, and until June 29, 1998, when
petitioners moved to Henderson, Nevada, their street address was
25521 La Mirada, Laguna Hills, California 92653-5316. This
address is hereinafter sometimes referred to as petitioners’
correct address, or as the 9-digit ZIP Code address. The only
difference between the two addresses is the addition of the
digits “217” to the end of the ZIP Code on the 9-digit ZIP Code
address. The 9-digit ZIP Code address appears on petitioners’
1996 tax return, which was filed on April 15, 1997. The 1996 tax
return was the last tax return petitioners filed before
respondent issued the notice of deficiency for 1995.
Petitioners did not receive the certified mail notice of
deficiency, nor was the certified mail notice of deficiency
returned to respondent. The U.S. Postal Service (hereinafter
sometimes referred to as the USPS) does not have any record of
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