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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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