- 3 - FINDINGS OF FACT The parties have stipulated some of the facts, and those facts are included herein by this reference. Other evidence was taken via testimony at trial. At the time of the filing of the petition, petitioner resided in Kingston, Illinois. Petitioner has not filed a Federal income tax return for the taxable year 1999. Pursuant to section 6020(b), respondent prepared a substitute for return for petitioner for the taxable year 1999 in July 2001. The substitute for return was based on information respondent received from third parties showing proceeds from sales of certain assets and interest income. On July 11, 2002, respondent mailed a notice of deficiency to petitioner related to the taxable year 1999, determining a deficiency in income tax and additions to tax attributable to the deficiency. Respondent used the address that petitioner had shown on the income tax return he filed for the taxable year 1997. The 1997 return was the last return petitioner filed before 2002. Petitioner did not notify the Internal Revenue Service of any change of address, and the July 11, 2002, notice of deficiency was returned by the U.S. Postal Service (USPS) to respondent. The envelope which contained the notice of deficiency was stamped by the USPS with the word “Unclaimed”.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011