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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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