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this examination, Stone informed Rausch that petitioner’s address
had changed to Henry, Virginia. The IRS entered this change into
its records but soon thereafter received petitioner’s 1997
Federal income tax return. This return bore the Woodside
address. Its receipt caused the IRS to change its records,
during the week of October 25, 1998, to reflect that petitioner’s
address was once again the Woodside address. That address
remained unchanged on IRS records until late in 2001, when
petitioner’s 1998 Federal income tax return was filed. In July
and in August 1999, when the 1995 and 1997 notices of deficiency
were mailed, IRS records indicated that petitioner’s address was
the Woodside address, the one appearing on his last-filed Federal
income tax return. There is no indication that either notice was
returned to the IRS undelivered, so there was no reason for the
IRS to conduct a further search for petitioner’s address.
(Petitioner speculated at trial that mail may have been stolen
from his mailbox at the Portola Valley residence. If that were
the case, however, it would not be attributable to any error on
the part of the IRS.)
In any event, petitioner did not move to Virginia. The
Virginia address was the address of Stone. Subsequent
correspondence between Dorr and Stone indicated that petitioner
continued to live in California while Stone lived in Virginia.
Moreover, a copy of the 1995 notice was sent to the Henry,
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