- 3 - certified mail two notices of deficiency addressed to both petitioners as to that year.3 Two of these notices were mailed to petitioners’ last known address (the Collins address) and received by them. The other two notices were mailed to petitioners’ former address (the Willow address), which, at the time, was the residence of petitioners' daughter and son-in-law; petitioners claim not to have received the latter two notices. All four notices are identical in all material regards, and each notice was mailed separately with a copy of Notice 1214, Helpful Contacts for Your “Notice of Deficiency”.4 None of respondent’s mailings were returned to him as undeliverable. During the first week of July 1999, Mr. Morgan retained Anne Tahim, a certified public accountant, to appeal respondent’s determination. On July 12, 1999, Ms. Tahim sent to the Internal Revenue Service by facsimile an executed power of attorney listing her and a colleague (collectively, the representatives) as petitioners’ representatives for petitioners’ 1995 through 1998 taxable years. Upon receiving the facsimile, an employee of respondent spoke to Ms. Tahim by telephone and, among other 3 An employee of respondent also hand delivered to Mr. Morgan on that date a copy of one of these notices. 4 Notice 1214 is a 2-page document that informs a person receiving a notice of deficiency that he or she may discuss the notice with the Internal Revenue Service employee listed on the face of the notice or with a local taxpayer advocate. The notice lists a toll-free number for taxpayer advocate assistance and the local phone numbers of the taxpayer advocate offices.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011