Peter Pettong and Chung-Yin Chiang - Page 4

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          petitioner was living at the Fort Worth address and asked that              
          the examination be moved to the IRS office in Fort Worth.                   
               On June 3, 1992, in a letter addressed to petitioners at the           
          Fort Worth address, the IRS requested that they reschedule the              
          meeting for the examination of their 1988 and 1989 returns.  In a           
          letter dated June 19, petitioner advised the IRS that he was in a           
          hospital in Wichita, Kansas, and expected to return to Texas as             
          soon as his health improved.  He asked that the examination be              
          rescheduled to September 28 or 29, 1992, at the Fort Worth                  
          office.  The IRS granted this request; however, 4 days before the           
          scheduled meeting, petitioner again contacted the IRS and asked             
          for a postponement.  In a letter dated September 24, 1992,                  
          petitioner informed the IRS that he had relocated to Wichita for            
          employment and requested that the examination be moved to the IRS           
          office nearest to his new residence at 9100 E. Harry # 2715,                
          Wichita, Kansas 67207.                                                      
               On October 7, 1992, the IRS office in Fort Worth sent                  
          petitioners a letter at their Wichita address informing them of             
          proposed adjustments to their 1988 and 1989 returns, and giving             
          petitioners 30 days to respond.  On October 20, 1992, the Austin            
          service center received petitioners' 1991 Federal income tax                
          return listing their residence as the Fort Worth address.  In the           
          occupation box, petitioner wrote "Engineer (Construction Fields),           
          three different short-term assignments in three locations, away             
          from home."  On November 25, 1992, petitioners met with Virginia            




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