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her last known address. See Yusko v. Commissioner, 89 T.C. 806,
808 (1987).
In connection with petitioners’ request for an Appeals
hearing, Appeals Officer Janice Rich prepared an Appeals case
memo, which is in evidence pursuant to the parties’ joint
stipulation. According to the Appeals case memo, the Appeals
officer verified that petitioners were sent proper notice and
demand for payment of their 1993, 1994, and 1995, tax
liabilities. Specifically, the Appeals officer verified that, on
May 2, 2000, these notices were accepted by taxpayer’s
housekeeper at 25 South Clancy Lane, Rancho Mirage, California,
which was petitioners’ last known address on respondent’s
computer database.5 The Appeals officer also verified that on the
same date (May 2, 2000), these notices were also mailed via
regular mail individually, and certified mail individually, to
the same address.
Petitioners have not challenged this verification, except in
these two respects: First, petitioners claim that on May 2,
2000, their legal residence was P.O. Box 1405, Rancho Mirage,
California. Petitioners presented no evidence, however, that
respondent was given notice of that address on or before May 2,
5 The Appeals officer also verified that petitioners were
given notice for their 1997 and 1998 tax years on May 15, 2000,
the date their 1997 and 1998 Federal income tax returns were
processed. Petitioners raised no challenge to that verification.
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