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released around July 14, 1998. Upon his release, petitioner
moved to 1536 Avenida Rosa, Chula Vista, California, 91911
(Avenida Rosa address).
In July 1998, respondent sent petitioner a 30-day letter
advising him of proposed adjustments to his 1996 Federal income
taxes. This letter was mailed to the Union Street address listed
on petitioner's 1997 return.
In response to this letter, petitioner returned to
respondent a preprinted form, which came with the 30-day letter,
and a two-page handwritten letter. On the preprinted form,
petitioner's Union Street address was typed as petitioner's
address. Petitioner did not make any corrections to the address
on this form, but he did list his phone number and his hours of
availability. Petitioner's handwritten letter did not include an
address or any reference to an address. On the front of the
envelope which petitioner mailed back to respondent, the Avenida
Rosa address was written in as the return address. On the back
of this envelope is a preprinted form which states: "COMPLETE
AND RETURN THIS PORTION IF YOUR ADDRESS HAS CHANGED". There are
spaces for the taxpayer's name, the taxpayer's identification
number, and the new address. Petitioner left this form blank.
The correspondence was received by respondent on July 31, 1998.
On September 9, 1998, respondent sent the notice of
deficiency by certified mail to petitioner at the Union Street
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Last modified: May 25, 2011