5
Grant, an IRS auditor in the Fort Worth office, to discuss
respondent's proposed adjustments to their 1988 and 1989 returns.
In a letter dated December 15, 1992, and sent to petitioners at
their Fort Worth address, Ms. Grant asked for additional
documentation for purposes of the examination. On January 3,
1993, petitioner wrote to Shirley Wickwary, manager of the audit
division at the Fort Worth office, challenging the document
request and protesting the treatment they received during their
meeting with Ms. Grant. In this letter, petitioners listed their
address as the Fort Worth address.
The record in this case contains no further correspondence
between petitioners and respondent until June 22, 1993, when
respondent sent a notice of deficiency for 1988 and 1989 to the
Fort Worth address by certified mail. The notice of deficiency
was not returned to respondent; however, petitioners contend that
they did not receive the notice because they were residing at
2210 S. Oliver Street, Apartment 318 in Wichita, Kansas (the
Oliver Street address), from January 1993 to October 14, 1993.
On August 16, 1993, respondent received petitioners' application
for an extension of time to file their 1992 return, wherein they
listed their address as the Fort Worth address. On October 25,
1993, respondent received petitioners' 1992 return, listing their
address as the Fort Worth address. A notice of deficiency for
tax year 1991 was sent to petitioners at the Fort Worth address
by certified mail on December 1, 1993. Petitioners claim to have
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