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petitioners' 1992 tax return was the last tax return filed by
petitioners before the notice of deficiency was issued.
The Girard St. address is the address listed by petitioners
on a Form 4868 (Application for Automatic Extension of Time To
File U.S. Individual Income Tax Return) in respect of the taxable
year 1993. The Form 4868 was filed with respondent on April 15,
1994. The Girard St. address is also listed as the address of
petitioner Manjit S. Aulakh in a stipulated decision that said
petitioner executed on April 1, 1994, and that was subsequently
entered by this Court in Aulakh v. Commissioner, docket No.
15875-93S.
The envelopes bearing the duplicate notices of deficiency
that were mailed to the Hale St. address and to the Girard St.
address were returned to respondent by the U.S. Postal Service on
June 16, 1994, marked "Unclaimed".
On April 10, 1995, respondent mailed petitioners a Notice of
Intent to Levy in respect of their tax liability for 1992.
Petitioners attached the Notice of Intent to Levy to their
imperfect petition, which was filed with the Court on May 1,
1995. Such petition was delivered to the Court in an envelope
bearing a U.S. Postal Service postmark date of April 21, 1995.2
Petitioners subsequently filed a proper amended petition.
2 At the time that the petition was filed with the Court,
petitioners resided at 2420 San Bruno Ave., San Francisco, CA.
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