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his refusal to accept delivery of correspondence from
respondent.3 On October 9, 1995, respondent assessed additional
tax, additions to tax, and interest against petitioner for 1990
and 1991.
On February 16, 1996, respondent mailed to petitioner a
notice of deficiency for 1992 and 1993. Respondent sent the
notice to the following address: Salvatore A. D’Onofrio, 676
Catalina Street, Laguna Beach, CA 92651-2545. Petitioner again
refused to accept delivery of the notice, and on February 23,
1996, respondent received the returned notice of deficiency with
the words “Refused for Cause UCC 3-501 Without Dishonor”
handwritten on the envelope.
Petitioner failed to petition this Court with respect to the
April 14, 1995, and February 16, 1996, notices of deficiency.
On June 1, 2005, respondent sent petitioner a Final Notice
of Intent to Levy and Notice of Your Right to a Hearing for 1990,
1991, 1992, and 1993. In response, petitioner timely submitted a
Form 12153, Request for a Collection Due Process Hearing.
Petitioner indicated that he disagreed with the proposed levy and
requested an audiotaped face-to-face hearing. Petitioner did not
provide a phone number in his request.
3In the letters, petitioner argued that he did not have an
“address” but listed a mailing location at which he could be
reached: “Salvatore A. D’Onofrio, Non Domestic Mail, c/o 676
Catalina, Laguna Beach, California”.
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