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Petitioner testified that a change of address in the
decedent's name was submitted to the United States Postal Service
and that she never received the NBAP or FPAA. Petitioner argues
that, had the notices been addressed to her, she would have
received them. Petitioner's assertion that mail addressed to
Alexander Locke, M.D., was not delivered to her home was
contradicted by petitioner's own testimony. She testified that
she and her son, also Alexander Locke, M.D., received an
"extremely high volume of mail". Nonetheless, petitioner failed
to provide the IRS with additional information in a manner
prescribed by the regulations. The notices that were mailed to
the address of the decedent as shown on the partnership return
were valid under these circumstances. Petitioner and her husband
having filed a joint tax return, notice to him is deemed notice
to her unless she instructed the IRS to send her a separate
notice, which she evidently never did. Olson v. Commissioner,
T.C. Memo. 1996-385; see sec. 301.6231(a)(2)-1T(3), Temporary
Proced. & Admin. Regs., 52 Fed. Reg. 6790 (Mar. 5, 1987).
Petitioner contends that the partnership item was converted
into a nonpartnership item because she did not receive the NBAP
or FPAA and, therefore, the statute of limitations for the
partnership item does not apply and the period of limitations for
a nonpartnership item had expired prior to assessment. Section
6231(b) lists the events that change partnership items to
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