Michael P. and Dolores A. Gam - Page 3




                                         - 3 -                                          
          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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