- 2 -
duplicate notice of deficiency to each petitioner for 1996, and
neither petitioner petitioned the Court with respect thereto.
We must decide whether respondent may proceed with the
proposed levy. We hold he may. Section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Most facts were stipulated. We incorporate by this
reference the parties’ stipulations of fact and the accompanying
exhibits. We find those facts accordingly. Petitioners resided
in California when the petition commencing this proceeding was
filed.
On August 4, 1997, respondent received petitioners’ joint
1996 Federal income tax return. Petitioners reported on that
return that their home address was 2205 Hilltop Drive #147,
Redding, California 96002 (Hilltop address). The Hilltop address
was a private mailbox at which petitioners sometimes received
mail. Since 1996, petitioners have also used a mailing address
at 1137 B Hartnell Avenue in Bella Vista, California (Hartnell
address).
Respondent received petitioners’ 1998 Federal income tax
return on October 20, 1999, petitioners’ amended 1998 Federal
income tax return on February 4, 2000, and petitioners’ 1999
Federal income tax return on October 12, 2000. Petitioners
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011