Michael T. & Leone Carey - Page 2




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          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                 






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