Patricia Ann Blocker - Page 5

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               Petitioner contends that she filed a timely Federal income             
          tax return for 1989 showing an address on Jeanetta in Houston,              
          Texas, where she had lived “since 1988".  Records of the IRS                
          consistently reflect that no return was filed for 1989 until the            
          return filed by petitioner in 2000.  Petitioner’s assertion with            
          respect to timely filing is uncorroborated.  In 1990, petitioner            
          married Blocker, and they failed to file returns for several                
          years thereafter.  On this record, we cannot accept petitioner’s            
          testimony that she filed a timely return for 1989.  In addition,            
          we can give no credence to the deductions that petitioner claimed           
          on her amended return for 1989 filed in 2004, because she has               
          presented no evidence to substantiate those deductions.                     
               Whether petitioner’s underlying liability exists, therefore,           
          depends on whether the amounts assessed in 1994 were validly                
          assessed, which depends in turn on whether the statutory notice             
          of deficiency sent November 24, 1993, was sent to petitioner’s              
          last known address.  IRS records reflect the Roydon Drive address           
          from 1989 through the delinquent filing of returns by petitioner            
          and Blocker in 1998.  Petitioner has presented no evidence that             
          she gave clear and concise notice of a change of address to the             
          IRS at any time prior to 1998.                                              
               Petitioner does not deny that she lived at the Roydon Drive            
          address in Houston at some time.  Her testimony is vague about              
          where she lived at any time and is uncorroborated by any records.           

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