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Also in the spring of 1992, Evelyn Napolitano (Revenue Agent
Napolitano), another revenue agent in Florida, contacted peti-
tioners regarding the collection of employment tax from peti-
tioner's professional corporation, Charles T. Phillips, P.C.
Around May 6, 1992, petitioners informed Revenue Agent Napolitano
of their impending move to the Bayou Glen address. Based on
petitioner's statements to Revenue Agent Morgan and Revenue Agent
Napolitano, petitioners' address was changed to the Bayou Glen
address on the Internal Revenue Service's computer records by
September 1992.
In June 1992, after petitioners moved to the Bayou Glen
address, the CPMC audit was transferred from Revenue Agent Morgan
to Revenue Agent Myers. Also in the spring of 1992, the employ-
ment tax collection matter was transferred to Revenue Officer
Herma Mills (Revenue Officer Mills). Neither Revenue Agent Myers
nor Revenue Officer Mills was aware at any time during the years
in issue of each other's investigation of these tax liabilities.
On August 4, 1992, Revenue Officer Mills informed petition-
ers by a certified letter addressed to Charles T. Phillips, P.C.,
at the Bayou Glen address, of the Internal Revenue Service's
intention to make a levy against the assets of that corporation
to satisfy unpaid employment tax liabilities for all of 1990 and
the first 3 quarters of 1991. Petitioner signed the return
receipt for this letter on August 7, 1992.
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