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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”.
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