- 7 - that I can process them. Please return as soon as possible. On March 4, 1993, before the Internal Revenue Service had received petitioner's signed 1989 and 1990 tax returns, respondent prepared a substitute return for petitioner's taxable year 1990, as authorized by section 6020(b). On the basis of this substitute return, respondent issued a notice of deficiency to petitioner for taxable year 1990. Respondent mailed the notice of deficiency by certified mail to petitioner's last known address. Petitioner did not claim the notice from the U.S. Postal Service and it was returned unopened to respondent by the Postal Service on June 25, 1993. On October 4, 1993, after attempting to reach petitioner by telephone on two occasions and after writing to petitioner about the unfiled returns, a second revenue agent received copies of petitioner's 1989 and 1990 tax returns. The copy of each return received by the agent is identical to the photocopy that petitioner previously had provided to the former revenue agent, except that it also bears petitioner's original signature and the date, October 1, 1993. Respondent's transcript of petitioner's account for 1989 states that petitioner's 1989 return was filed onPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011