Wilburn C. Hall, Jr. - Page 12

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          tax return Classen address; (3) he had not received any notices             
          regarding the assessment of additional taxes; (4) he had advised            
          respondent previously that his mailing address should be the P.O.           
          drawer address; and (5) respondent was aware that "There had been           
          some difficulty in receiving certified mail at" the tax return              
          Classen address.                                                            
          Petitioner's October 23, 1990, letter was received by                       
          respondent on October 25, 1990. An "en mod" search4 was made on             
          November 2, 1990, at 10:09 a.m. The first page of the report on             
          the en mod search shows the I.R.S. Classen address; the second              
          page does not show any address; the third page shows the P.O.               
          drawer address and another address, as follows: 124 E. MAIN                 
          NORMAN OK 73069 (hereinafter sometimes referred to as the E. Main           
          address). Petitioner maintained a law office at the E. Main                 
          address from about 1982 through about 1984. (In or about 1984,              
          petitioner moved his law practice to Tulsa from the E. Main                 
          address, in Norman. After about a year, he moved his law                    
          practice back to Norman.)                                                   
          On or about November 7, 1990, petitioner's October 23, 1990,                
          letter was referred to Janine MacKenzie, hereinafter sometimes              
          referred to as MacKenzie. An "amdissa", dated November 2, 1990,             
          10:41 a.m., was attached to petitioner's October 23, 1990,                  
          letter, and indicates that a notice of deficiency had been sent             


               4An "en mod" search is an I.R.S. search through I.R.S.                 
          records for a taxpayer's most recently known address.                       



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