Filomena Pahamotang - Page 3

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          CA 92627 (P.O. Box address).  On April 7, 1998, respondent mailed           
          duplicate statutory notices of deficiency to petitioner--one to             
          the Adams Avenue address and the other to the P.O. Box address.             
          In those notices for petitioner’s 1994 tax year, respondent                 
          determined a $53,680 income tax deficiency and a $10,736 penalty            
          under section 6662(a).1  The deficiency results from respondent’s           
          determination that petitioner was not entitled to certain claimed           
          business and itemized deductions.  The notice sent to the Adams             
          Avenue address was returned to respondent marked “Moved, Left No            
          Address”.  The notice sent to the P.O. Box address was not                  
          returned to respondent.                                                     
               On June 23, 1998, respondent received a letter from                    
          petitioner indicating that she wanted to appeal respondent’s                
          determinations for 1994 and 1995.  Petitioner’s letter attached a           
          copy of the first pages of respondent’s notices of deficiency for           
          1994 and 1995, but only for the notices sent to the P.O. Box                
          address.  Petitioner’s letter to respondent reflected her then              
          current address as the P.O. Box address.  Petitioner did not                
          petition this Court with respect to the 1994 notice, and on                 
          August 31, 1998, respondent assessed the income tax deficiency              
          and penalty.                                                                



               1 Section references are to the Internal Revenue Code in               
          effect for the period under consideration.                                  





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