Charles T. and Joan B. Phillips - Page 6

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               On August 27, 1992, Revenue Officer Myers informed peti-               
          tioners, by letters addressed to petitioners at the Bayou Glen              
          address and the Merritt Island address, that he was beginning               
          audits of petitioners' Federal individual income tax returns for            
          the 1989 and 1990 tax years.  The letter to the Bayou Glen                  
          address was sent by certified mail, and the return receipt for              
          that letter was signed by petitioner on August 31, 1992.  The               
          certified letter sent to the Merritt Island address was returned            
          unclaimed.  Although petitioners received the August 27, 1992,              
          letter, they never contacted Revenue Agent Myers regarding this             
          letter, and Revenue Agent Myers sent no further correspondence to           
          petitioners.  By February 1993, Revenue Agent Myers finished the            
          examination of petitioners' 1987, 1988, and 1989 tax years.                 
               On October 5, 1992, Mrs. Phillips mailed a Form 3575, change           
          of address form, to the U.S. Postal Service, indicating that                
          petitioners were moving from the Bayou Glen address to 5376                 
          Brownway in Houston, Texas (the Brownway address).  Petitioners             
          never notified the Internal Revenue Service of their move to the            
          Brownway address.                                                           
               On November 4, 1992, Revenue Officer Mills made a field call           
          to the Bayou Glen address and was told by the property manager              
          that petitioners had moved.  Revenue Officer Mills then filed a             
          request for new address with the U.S. Postal Service.  The Postal           
          Service informed Revenue Officer Mills of petitioners' new Brown-           
          way address.                                                                




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