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bears the handwritten and encircled word “Deceased”. It is not
clear from the record who wrote “Deceased” or when it was
written. Also, the U.S. Postal Service Form 3811 attached to the
envelope in which the notice of deficiency was mailed reflects an
illegible and crossed out signature on the line marked as
“Signature (Agent)”.
On the same date respondent mailed a duplicate notice of
deficiency to “Pericles G. Nichols (Decd) and Emily T. Nichols”,
P.O. Box 2085, Palm Beach, Florida 33480 (the Palm Beach
address). The notice of deficiency mailed to the Palm Beach
address was returned to respondent unopened and marked as
“Forwarding Order Expired”.
On April 13, 1995, respondent mailed a notice of deficiency
for the 1991 tax year to “Pericles G. Nichols (Decd) and Emily T.
Nichols”, 999 Ponce de Leon Boulevard, Coral Gables, Florida
33134 (the Coral Gables address). The notice of deficiency dated
April 13, 1995, was mailed to the Coral Gables address and was
otherwise identical to the notices mailed on December 8, 1994.
Respondent explained that, upon receipt of the returned notices
of deficiency mailed on December 8, 1994, he became aware that
petitioner did not receive either of the duplicate notices of
deficiency and decided to mail the notice of deficiency for the
1991 tax year to an additional address. This notice of
deficiency was returned to respondent unopened, marked as “Return
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