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Petitioner resided in Millington, Tennessee, at the time she
filed the petition in this case.
Petitioner timely filed a Federal income tax (tax) return
for her taxable year 2000 (2000 return). Respondent conducted an
examination of petitioner’s 2000 return. On April 18, 2002,
respondent mailed a 30-day letter (respondent’s 30-day letter) to
petitioner at the following address: 2839 Coach Drive, Apartment
3, Memphis, Tennessee 38128. On May 22, 2002, respondent re-
ceived correspondence from petitioner.
Thereafter, on October 29, 2002, respondent mailed to
petitioner at the address to which respondent mailed respondent’s
30-day letter a notice of deficiency with respect to petitioner’s
taxable year 2000, which she received. Petitioner did not file a
petition in the Court with respect to the notice of deficiency
relating to her taxable year 2000.
On April 21, 2003, respondent assessed petitioner’s tax as
well as interest as provided by law for her taxable year 2000.
(We shall refer to any such unpaid assessed amounts, as well as
interest as provided by law accrued after April 21, 2003, as
petitioner’s unpaid liability for 2000.)
Respondent issued to petitioner a notice of balance due with
respect to petitioner’s unpaid liability for 2000, as required by
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Last modified: May 25, 2011