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To File U.S. Individual Income Tax Return for 1988. The Form
4868 listed petitioner’s address as the Portola Valley address.
The Form 4868 did not contain petitioner’s Woodside address, nor
did it state that the application was intended as a notification
of a change of address. The IRS did not receive a 1998 Federal
income tax return from petitioner until May 14, 2001. This was
the first time that petitioner had submitted a Federal income tax
return that reflected petitioner’s Portola Valley address.
Petitioner’s taxable year 1998 is not otherwise before the Court.
Petitioner’s Suit for Damages
Petitioner had some complaints about IRS collection
activities. Petitioner and Stone contacted the Office of the
Taxpayer Advocate concerning petitioner’s complaints. They
visited that office in Washington, D.C., in February 1999 and
provided the Portola Valley address to Sharese Stevens of that
office. He filed an administrative claim for damages with the
District Director in Oakland, California, on July 15, 1999. The
claim listed petitioner’s address as the Portola Valley address.
The claim did not contain petitioner’s Woodside address, nor did
it state that the claim was intended as a notification of a
change of address.
At the request of the National Taxpayer Advocate,
consideration of petitioner’s administrative claim was
transferred from Oakland, California, to Seattle, Washington.
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