- 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. PetitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011