Patricia Ann Blocker - Page 6

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          The only thing clear is that she moved many times.  She contends            
          that she lived with her former husband for a few months in 1988,            
          that she lived on Westerland Avenue at the time of her divorce,             
          and that she lived at the Jeanetta address in Houston commencing            
          in 1988.  Respondent contends, without persuasive evidence in the           
          record, that petitioner rented the Roydon Drive address beginning           
          in 1989 and then provided that address to the IRS.  Given                   
          petitioner’s failure to communicate with the IRS, it is more                
          likely that the Royden Drive address was shown on a return filed            
          for 1988.  In any event, prior to 1993, the Roydon Drive address            
          was the address for petitioner reflected in IRS records, which              
          were not changed again until 1998.                                          
               Petitioner also claims that the statutory notice should have           
          been mailed to a Bering Drive address, which was used on a letter           
          sent to petitioner in August 1993.  There is no explanation in              
          the record as to how that address would have become known to the            
          IRS.  The Bering Drive address was not the address shown on any             
          return filed by petitioner, and there is no evidence as to                  
          whether or when she lived at that address.  The Bering Drive                
          address thus cannot be considered her last known address.                   
               Petitioner contends that the IRS should have mailed the                
          notice of deficiency or remailed the notice of deficiency to the            
          Jeanetta address shown on the Forms W-2 for 1989 sent to the IRS            
          by third-party payers of the income.  Respondent argues that                

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