Polly Paul McMahon - Page 5

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          to contact Mail Boxes, Etc., periodically for the purpose of                
          having such mail forwarded to him at his new location.  Mail                
          Boxes, Etc., moved its facilities from 4524 Forsyth Rd., Suite              
          201, in Macon, Georgia, to 5962 Zebulon Rd., #201, in the same              
          city.                                                                       
          On November 15, 1995, respondent mailed a notice of                         
          deficiency to petitioner by certified mail determining                      
          deficiencies in and additions to petitioner's Federal income                
          taxes for the years and in the amounts as follows:                          
                                   Additions to Tax                                   
               Year   Deficiency   Sec. 6651(a)(1)   Sec. 6654                        
               1991    $59,408         $14,668         $3,387                         
          1992     82,876          20,684          3,613                              
          1993     24,969           6,217          1,041                              
          The notice of deficiency was mailed to petitioner at the 2162               
          Ingleside Avenue address.  On November 16, 1995, the notice of              
          deficiency was forwarded to 2411 Ingleside Avenue.  On November             
          17, 1995, the notice of deficiency was forwarded to Mail Boxes,             
          Etc., 4524 Forsyth Rd., Suite 201, Macon, Georgia.  On November             
          22, 1995, the notice of deficiency was forwarded to Mail Boxes,             
          Etc., 5962 Zebulon Rd., #201, Macon, Georgia.  On November 24,              
          1995, Christie Shackleford, an employee of Mail Boxes, Etc.,                
          accepted delivery of the envelope bearing the notice of                     
          deficiency.                                                                 
               The envelope bearing the notice of deficiency was eventually           
          forwarded to petitioner in Spokane, Washington.  The record does            




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