Manjit S. and Ravinder K. Aulakh - Page 3

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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.                 
          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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