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(the Oak Creek address). Enclosed with the letter were copies of
Forms K-1 that PTSI had prepared for petitioner for the taxable
years 2000 through 2004.
Petitioner testified that he also sent a letter to Mr. Stern
at the Grayslake address in 2005 (petitioner’s 2005 letter).6
The record does not establish precisely when petitioner sent the
2005 letter, although attachments to his pretrial memorandum
indicate it was in November 2005. Petitioner claims that his
2005 letter also was returned to him and marked “Unable to
forward”. Petitioner believes the return of his 1999 and 2005
letters demonstrates that Mr. Stern “refused to accept any
correspondence” from petitioner.
We are skeptical of petitioner’s contentions regarding
PTSI’s alleged disappearance. First, PTSI remained an active
business in the Chicago metropolitan area7 until 2004, which
petitioner acknowledged at trial. Such ongoing operations are
inconsistent with the theory that PTSI was attempting to conceal
itself from petitioner. Even if PTSI had been trying to conceal
itself, it is difficult to believe that petitioner could not have
located PTSI had he made reasonable efforts to do so.
6 It is not clear why petitioner mailed this letter to the
Grayslake address rather than the Oak Creek address listed in Mr.
Stern’s letter. We assume that petitioner sent his 2005 letter
before receiving a copy of Mr. Stern’s letter from respondent.
7 Both Glenview, Ill. and Grayslake, Ill. are located north
of Chicago.
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