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the revised examination report informed petitioner that he had 15
days from November 4, 2003, the date of the letter, to request a
conference with the Appeals Office. The letter also informed
petitioner that respondent would issue a notice of deficiency if
petitioner did not request a conference within the 15-day period.
Petitioner did not submit a timely request for an Appeals
conference. Consequently, on January 6, 2004, respondent issued
a notice of deficiency (notice) to petitioner for 2001. The
notice was addressed to 814 North Market Street, Apartment 5,
Inglewood, CA 90302-5931.4
On February 20, 2004, petitioner mailed Form 12203, Request
for Appeals Review (Request), to respondent. On a date that does
not appear in the record, respondent forwarded petitioner’s
Request to this Court.5 By letter dated April 5, 2004,
3(...continued)
specifically identified in the record.
4Petitioner disputes receipt of the notice, but he admits
that he received other correspondence from respondent at the
North Market Street address. Petitioner’s Request and his
amended petition both show the North Market Street address as his
current address.
5Respondent’s postage meter stamp on the envelope in which
the Request was forwarded reads Apr. 2, 2004. However,
respondent contends that the Request was mailed “On or about
April 8, 2004”. The U.S. Postal Service stamp is illegible. If
the Request took no more than the ordinary delivery time of 3
days for a mailing from California to Washington, D.C. (see
discussion, infra pp. 5-8), the latest date on which the Request
could have been mailed to arrive at the Court on Apr. 12, 2004,
was Apr. 9, 2004.
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Last modified: May 25, 2011