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Year Petitioners Failed To
1998 Timely file their return
Timely pay the tax liability stated on the return
1999 Timely pay estimated taxes
Timely pay the tax liability stated on the return
2000 Timely pay the tax liability stated on the return
2001 Timely file their return
Timely pay the tax liability stated on the return
2002 Timely pay estimated taxes
Timely pay the tax liability stated on the return
In April 2000, petitioners moved to a new address, but
petitioners did not notify respondent of their change of address.
Before this move, petitioners filed with respondent IRS Form
2848, Power of Attorney and Declaration of Representative, in
which petitioners directed respondent to send to petitioners’
representative copies of any correspondence sent to petitioners.
Petitioners’ 2000, 2001, and 2002 Federal income tax returns
filed with respondent continued to show petitioners’ old address
and did not show the new address to which petitioners moved in
April 2000. Petitioners did not otherwise notify respondent of
their new address until sometime after March 2004.
From November 2002 through January 2004, respondent sent to
petitioners (at the old address shown on petitioners’ 2000, 2001,
and 2002 Federal income tax returns; namely, 23382 Via Chirpia,
Mission Viejo, CA) at least seven notices relating to various
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Last modified: March 27, 2008