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for 2003 listing the Rocco address. The 2003 Form 1040 is not
part of the record. Even if the Form 1040 were part of the
record, the Rocco address shown on the Form 2688 and allegedly
shown on the Form 1040 was not the Bedrosians’ most current
address. Olson updated respondent subsequent to the filing of
the Bedrosians’ Form 1040 for 2003 by notifying Revenue Agent
Smyth as to the North Canon and Beverly Glen addresses.
Petitioner further argues that respondent sent a series of
correspondence to the Bedrosians at the Rocco address and
therefore was aware of the Rocco address and had the Rocco
address in respondent’s information base. Additionally,
petitioner notes that the Computer Generated Form 886-Z(C),
Partner’s or S Corporation Shareholders’ Shares of Income, that
was attached to the FPAA listed the Rocco address for both
Investors and JCB. Although respondent was aware of the Rocco
address and in fact used the Rocco address on the Form 886-Z(C),
the FPAA itself was not required to be sent there. Triangle
Investors Ltd. Pship. v. Commissioner, 95 T.C. at 616. Pursuant
to section 301.6223(c)-1T(f), Temporary Income Tax Regs., supra,
respondent is not obligated to search his records for
information not expressly furnished. Petitioner did not follow
the procedure in the regulations, and as a result respondent was
not obligated to search his records for information when sending
the FPAA. Furthermore, the Beverly Glen address was a proper
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