Keith and Cherie Orum - Page 13

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          Other Specified Matters, for 1998, which reported that the notice           
          of intent to levy was issued on June 23, 2000, and a return                 
          receipt was signed on June 26, 2000.  That certificate is                   
          “generally regarded as being sufficient proof, in the absence of            
          evidence to the contrary, of the adequacy and propriety of                  
          notices and assessments that have been made.”  Gentry v. United             
          States, 962 F.2d 555, 557 (6th Cir. 1992); see Schroeder v.                 
          Commissioner, T.C. Memo. 2002-190; Kaeckell v. Commissioner, T.C.           
          Memo. 2002-114.  Further, respondent provided an ACS LT11                   
          Certified Mail List for 1998 which reported that a Notice of                
          Intent to Levy and Notice of Your Right to a Hearing was sent to            
          petitioners by certified mail at “LaGrange Park, IL 60526-134603"           
          on June 23, 2000.  See Weber v. Commissioner, 122 T.C. 258, 259             
          n.3 (2004).                                                                 
               We also note that the parties stipulated that petitioners              
          filed a tax return for 1998 before the June 23, 2000, notice was            
          issued, and Mr. Orum reported on his offer-in-compromise                    
          application that he had been “current” with his tax liabilities             
          from 1981 until 1998.  Mr. Orum stated on his Form 433-A that he            
          has lived at the same address his entire life.  On the basis of             
          the record and the Commissioner’s practice of using the address             
          of a taxpayer’s most recently filed tax return as the last known            
          address, we find that the address used for the June 23, 2000,               
          notice was petitioners’ last known address.                                 






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