- 2 -2 filed November 6, 2000, and petitioner’s Notice of Objection, filed December 4, 2000. The parties appeared and were heard. Background In a statutory notice of deficiency dated April 29, 1998, respondent determined a deficiency in petitioner’s Federal income tax for the year 1995 in the amount of $9,076, and a penalty pursuant to section 66621 in the amount of $640. The notice of deficiency was mailed, by certified mail, to petitioner’s last known address: 359 Greenway Drive, Pacifica, California, 94004-2920592. The notice of deficiency, dated April 29, 1998, was returned to the Internal Revenue Service as unclaimed, after the U.S. Postal Service had waited 15 days for petitioner to claim the letter. The U.S. Postal Service attempted to deliver the notice of deficiency to petitioner on May 1 and 6, 1998. At the January 22, 2001, hearing in this case, respondent represented to the Court: In this case, the exhibits attached to our motion show that the IRS issue of the stat notice to the petitioner at his last known address, that the Post Office attempted delivery several times, and that petitioner did not pick up -- refused to pick up the statutory notice of deficiency. And apparently the reason as set forth in this objection, where he indicated he shouldn’t have to take 1 All section references are to the Internal Revenue Code currently in effect.Page: Previous 1 2 3 4 5 6 7 8 Next
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