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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.
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