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On July 11, 2002, respondent mailed a duplicate notice of
deficiency to petitioner at another address. This second notice
of deficiency was also returned by the USPS, and the envelope
containing it was stamped “Unclaimed”. The second notice was
mailed on the basis of respondent’s attempts to find petitioner’s
current address using a “postal tracer research” procedure
provided by the USPS.
Petitioner did not reside at either of the addresses to
which the notice of deficiency was mailed on July 11, 2002, and
petitioner did not receive the notice of deficiency. As a
result, petitioner did not file a deficiency suit with this
Court. Respondent assessed the income tax deficiency and the
additions to tax on December 9, 2002. On December 9, 2002, and
January 13, 2003, petitioner was issued a notice of demand for
payment of the tax liability and the additions to tax for 1999.
On November 28, 2003, respondent filed with the Recorder of
Deeds, DeKalb County, Illinois, a notice of Federal tax lien with
respect to petitioner’s tax liability and the additions to tax.
On December 4, 2003, respondent mailed to petitioner at a third
address in Kingston, Illinois, a notice of Federal tax lien
filing with respect to the lien filed for the taxable year 1999.
On or about January 5, 2004, respondent received a timely Form
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Last modified: May 25, 2011