Sandra L. Andary-Stern - Page 18




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          petitioner’s own unreasonable conduct, the failure to file                  
          returns or to otherwise notify respondent of any address changes,           
          and respondent’s conduct throughout the course of the                       
          administrative proceeding, which we find was reasonable.                    
               Petitioner states that she “had no knowledge of any taxes              
          owed and IRS did nothing to inform [her] of any taxes owed.”  It            
          bears repeating that our scheme of taxation is premised on “self-           
          assessment” through the filing of returns, Sloan v. Commissioner,           
          102 T.C. 137, 146 (1994), affd. 53 F.3d 799 (7th Cir. 1995), and            
          it is the taxpayer’s obligation to inform the Commissioner of               
          taxes owed.  Petitioner emphasizes that the Forms W-2 filed by              
          her former employers had the correct addresses.  It therefore               
          follows that petitioner received the Forms W-2 and that                     
          petitioner knew or should have known she was required to file               
          returns.  By failing to file returns, as the law requires her to            
          do, or to otherwise notify respondent of her address changes,               
          petitioner bears much of the responsibility for not having                  
          received the notices of deficiency.                                         
               Respondent acted reasonably when petitioner brought to his             
          attention that she had not received the notices of deficiency.              
          When petitioner contacted the Taxpayer Advocate Service in                  
          December 2000, the period of limitations on assessment had not              
          started to run because petitioner had not filed returns.  Sec.              
          6501(c)(3).  Accordingly, respondent could have reissued the                






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