Warren Richard Follum - Page 3

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               In early August 1995, petitioner closed the Wilmington post            
          office box and moved to 4997 Creek Road, Lewiston, New York (the            
          Lewiston address).                                                          
               On August 29, 1995, respondent mailed a letter to petitioner           
          at the Wilmington address stating that petitioner's tax returns             
          for 1990, 1991, 1992, and 1993 had been selected for audit and              
          requesting that petitioner appear at respondent's offices in                
          Wilmington on September 26, 1995.  Petitioner maintains that he             
          did not receive this letter.  Respondent's files do not indicate            
          that the letter was returned to respondent undelivered.                     
               On September 27, 1995, respondent issued a second letter to            
          petitioner at the Wilmington address proposing adjustments to               
          petitioner's taxes for the years 1990, 1991, 1992, and 1993.                
          Petitioner maintains that he did not receive this letter.                   
          Respondent's files do not indicate that the letter was returned             
          to respondent undelivered.                                                  
          On November 3, 1995, respondent mailed two separate notices                 
          of deficiency2 to petitioner determining deficiencies in and an             
          addition to his Federal income taxes for the taxable years 1990,            
          1991, 1992, and 1993 as follows:                                            




          2  One of the notices includes the determination for 1990, and              
          the other notice includes the determination for 1991, 1992, and             
          1993.                                                                       




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