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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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