Gary Friedmann - Page 7




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                  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 on                   






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