Alfred J. Martin - Page 6




                                        - 6 -                                         
          known address.  Petitioner received the notice of deficiency.  He           
          wrote a letter to Zobrist on May 20, 1986, in which he said that            
          he was a limited partner in Winchester Oil and asked for advice.            
          Petitioner attached a copy of the 1986 notice of deficiency to              
          that letter.  On July 25, 1986, Zobrist sent a letter to                    
          petitioner and Rothhammer informing them that a petition had been           
          mailed on their behalf and enclosing a copy.  The petition was              
          filed on August 4, 1986, at docket No. 32146-86.                            
               2.   Tax Year 1980 (Docket No. 22961-88)                               
               On June 7, 1988, respondent sent a notice of deficiency for            
          1980 addressed to both petitioners at P.O. Box 886, Suffolk,                
          Virginia 23434, petitioner’s last known address, and to both                
          petitioners at Rothhammer’s Colorado Springs address.  The U.S.             
          Post Office returned to respondent the envelope containing the              
          notice that had been sent to Suffolk, Virginia.  The envelope was           
          marked “undeliverable as addressed, no forwarding order on file.”           
          Respondent sent to Covalt, and Covalt received, a copy of that              
          notice of deficiency.  On June 20, 1988, Covalt wrote a letter to           
          Zobrist (copy to Rothhammer) stating that respondent had sent a             
          notice of deficiency for 1980 to Rothhammer and petitioner and to           
          ask Zobrist to contact Rothhammer.  Covalt also wrote a letter to           
          Robb (copy to Rothhammer) on June 20, 1988, in which he enclosed            
          a copy of the notice of deficiency for 1980 to ensure that Robb             
          knew that respondent had sent it to petitioner.                             
               On August 29, 1988, Berg signed the petition for taxable               




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011