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address, 80 North Star Trail, Atlanta, Georgia 30331-7862
(hereinafter referred to as the 80 North Star Trail address). That
notice detailed respondent’s determinations regarding income tax
deficiencies, additions to tax, and penalties for 1990 and 1991, as
follows:
Addition to Tax Penalty
Year Deficiency Sec. 6651(a)(1) Sec. 6662(a)
1990 $19,680 $5,455 $3,936
1991 23,616 --- 4,723
The U.S. Postal Service (USPS) returned the notice of
deficiency to the IRS on April 27, 1995. The envelope in which the
notice of deficiency was mailed indicates that the USPS made but
one delivery attempt before returning the envelope and its contents
to the IRS as “unclaimed”.
Petitioners did not claim the certified letter containing the
notice of deficiency from the USPS because they did not receive
from the USPS notice of the existence of such letter. Had they
received a notice of certified mail, they would have gone to the
post office to pick up the letter.
Petitioners did not contest respondent’s determinations as set
forth in the notice of deficiency by filing a petition with this
Court. Had petitioners received the notice of deficiency, they
would have petitioned this Court for a redetermination of the tax
liabilities asserted in the notice of deficiency.
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Last modified: May 25, 2011