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California, respondent submitted a Request to Locate Person (PS
Form 3241) to the U.S. Postal Service on August 8, 1989. Later
that month, on August 18, 1989, respondent received a response
from the Postal Service indicating that petitioner’s address was
in Hemet, California. On that same day, respondent sent a 30-day
letter to petitioner in Hemet, proposing changes to petitioner’s
1986 return. The record suggests that this letter may not have
been received by petitioner.
On September 12, 1989, respondent sent a copy of the 30-day
letter to petitioner by certified mail, return receipt requested,
at an address in Clermont, Florida.6 The Postal Service Return
Receipt (PS Form 3811) reveals that the letter was received on
September 15, 1989, by an agent of the addressee.
In October 1989, respondent received a power of attorney
(Form 2848) from Mr. Amigron naming him as petitioner’s
representative. However, the signature on the power of attorney
purporting to be that of petitioner did not match petitioner’s
signature on other documents in respondent’s possession.
Accordingly, respondent’s Examination Division referred Mr.
Amigron to respondent’s Inspection Division. Respondent
continued to send all correspondence directly to petitioner.
On October 31, 1989, respondent sent a “final notice”
6 Prior to Sept. 12, 1989, Mr. Amigron had advised
respondent that petitioner was living in Florida.
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