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result of her own efforts in locating petitioner, she believed
the Brownway address to be his current address.
On February 24, 1993, Group Manager Ronald W. Hopper mailed
a letter prepared by Revenue Officer Mills to petitioner at the
Brownway address. The letter informed petitioner that the
Internal Revenue Service proposed to assess against him a penalty
under section 6672 and that, if he did not agree, he should
contact her within 10 days with additional information to support
his position. The letter also informed petitioner that he had a
right to appeal the determination within 30 days of the date of
the letter, and, if Revenue Officer Mills did not hear from him,
the penalty would be assessed against him. Petitioner did not
respond to the February 24, 1993, letter.
On March 19, 1993, Revenue Officer Mills received via fac-
simile, two powers of attorney from a certified public accountant
(C.P.A.) representing petitioner and Charles T. Phillips, P.C.
The powers of attorney listed the Brownway address as the peti-
tioners' current address. Revenue Officer Mills received no
other information from petitioner, and, in June 1993, Revenue
Officer Mills closed the audit of Charles T. Phillips, P.C., and
recommended a section 6672 assessment against petitioner for the
employment tax liabilities of the corporation. Although Revenue
Agent Mills believed the Brownway address was petitioners'
current address, she did not update respondent's computer files
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