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Settlement Officer Jacobi also determined that respondent timely
and properly mailed the notice of deficiency to petitioner at his
last known address and that petitioner failed to timely petition
the Tax Court.
Regarding petitioner’s claim that respondent failed to mail
petitioner a notice of deficiency, Settlement Officer Jacobi
determined the following: (1) Petitioner’s 1994 and 1995 audit
files contained a copy of the notice of deficiency dated August
11, 1999, addressed to petitioner at his last known address, 328
County Road, Madison, CT 06443-1640, and stamped “certified
mail”; (2) U.S. Postal Form 3877 reflected that, on August 11,
1999, respondent had delivered the notice of deficiency to the
post office for delivery to petitioner; (3) the certified mail
number on the notice of deficiency and the article number on the
Form 3877 next to petitioner’s name were the same number; and (4)
the notice of deficiency had not been returned to respondent.
On September 26, 2002, respondent’s Appeals Office issued a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330. The notice set forth the actions taken
by Settlement Officer Jacobi, addressed the issues raised by
petitioner, and determined that respondent’s proposed levy action
to collect petitioner’s assessed tax liabilities for the 1994 and
1995 taxable years should be upheld. The notice of determination
also determined that petitioner did not propose any collection
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