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1996.2 In this correspondence, petitioner listed an address in
New Hampshire.
In response, respondent sent a letter dated October 22,
2001, to petitioner’s New Hampshire address. The letter was
addressed to petitioner and a former spouse, Ruby L. Downing, but
the heading and caption of the letter referenced only
petitioner’s individual Social Security number. In the letter,
respondent advised that the IRS had received “your” 1995 Federal
income tax return but that it was not signed. The letter
requested that an enclosed declaration be signed and returned to
respondent within 20 days so the 1995 return could be processed.
In a letter to the IRS, dated November 15, 2001, petitioner
responded from the New Hampshire address that he was not signing
the declaration because he and Ruby L. Downing were not married
in 1995 and did not file a return in 1995. He stated that he had
previously supplied respondent a copy of “my 1995 return”.
Summary Assessment of Petitioner’s 1995 Income Tax
In the meantime, having received no response from petitioner
within the 20-day deadline stated in respondent’s October 22,
2001, letter, respondent had summarily assessed against
petitioner the $77,017 tax reported on the copy of petitioner’s
2 Also included with petitioner’s Apr. 11, 2001, letter was
a copy of Notice CP-515M, Information About Your Return,
completed and signed by petitioner under penalties of perjury.
On the Notice CP-515M, petitioner indicated that his filing
status for 1995 was married filing jointly.
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