In Uncategorized on 12/14/2018 at 16:35

A much more exalted personage even than Ch J Maurice B (“Mighty Mo”) Foley gives me the title for this blogpost, Michael T. Sestak, Docket No. 17286-18, filed 12/14/18, a special day in our house.

Mike claims IRS failed to send the SNOD to his last-known address.

IRS points to a handwritten letter from Mike that sets forth his address and directs that all correspondence be sent to him at Pine Knot, TN. Mike sent this two (count ‘em, two) years before the SNOD was mailed.

Mike claims he gave the IRS his complete address. IRS says no, Mike didn’t include Mike’s prison registration number.

Despite this season of goodwill, Ch J Mighty Mo isn’t letting IRS get by.

“… I.R.M. (07-09-2013) states, in pertinent part: Incarcerated Taxpayers *******

“2. The address in the Letter 531, Notice of Deficiency, should be where the taxpayer is incarcerated and should reference the prisoner locator number if available.

“3. For federal prison inmates, the prisoner locator number and address can be obtained from the Bureau of Prisons web site.” Order, at p. 2.

DC Cir has held that IRS should make a reasonably diligent effort to find out a party’s address if there’s doubt that the address they have won’t reach that party.

So let IRS explain why they didn’t check out Mike’s prisoner locator number.



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