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Background
Statutory notices with respect to 1993, 1994, and 1995 were
sent to each petitioner on August 13, 1997. Duplicate originals
were sent to Steven Sego; one of those was sent by certified mail
to an address in Spirit Lake, Idaho, and one was sent by regular
mail to the address in Rathdrum, Idaho, that is the address used
on the petition in this case. The statutory notice sent to
Steven Sego in Spirit Lake, Idaho, was returned undelivered by
the Postal Service. The statutory notice sent to Steven Sego by
regular mail was returned to respondent on October 10, 1997.
Handwritten across the first page of the returned statutory
notice were the words “This presentment Dishonored at UCC 1-207".
At the time the notice was returned to respondent by Steven Sego,
there remained 31 days for Steven Sego to petition the Tax Court.
He did not do so.
With respect to Davina Sego, respondent asserts that a
statutory notice of deficiency was sent to her for 1993, 1994,
and 1995 at the Rathdrum, Idaho, address, as shown by the
postmark stamped on the executed Application for Registration or
Certification, U.S. Postal Service Form 3877, a copy of which is
in the record. Respondent contends that, after leaving two
notices of certified mail in petitioners’ mailbox on August 18,
1997, and on August 25, 1997, the notice of deficiency was
returned to respondent by the Postal Service.
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Last modified: May 25, 2011