Roger L. Sherer - Page 3

                                        - 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