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(Rancho), and Sunshine. In 1996, Mr. Carey had sole signatory
authority on the bank accounts maintained for Home Health,
Residential, Rancho, and Sunshine.
Respondent mailed the subject notices of deficiency to
petitioners at the Lawrence address by way of certified mail.
The United States Postal Service (USPS) attempted unsuccessfully
to deliver the notices to that address on Monday, June 5, 2000,
and Tuesday, June 13, 2000, and returned the notices to
respondent on July 20, 2000. The USPS noted on the certified
envelopes that they were “unclaimed”. On October 30, 2000,
respondent assessed the amount of the deficiency and accuracy-
related penalty against petitioners.
On January 8, 2001, respondent mailed to petitioners as to
1996 a Letter 1058, Final Notice, Notice of Intent to Levy and
Notice of Your Right to a Hearing. Respondent mailed the letter
to the Lawrence address. One week later, respondent mailed to
petitioners as to 1996 a related Letter 3172, Notice of Federal
Tax Lien Filing and Your Right to a Hearing under IRC 6320. That
letter was also mailed to the Lawrence address.
On or about January 16, 2001, petitioners responded to
Letter 1058 by filing with the Commissioner a Form 12153, Request
for a Collection Due Process Hearing. Petitioners listed on this
form that their address was the Lawrence address and stated that
they planned to challenge the amount of the unpaid taxes which
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