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could either pick it up at the Post Office or have the mail
carrier attempt delivery again. Mr. Horton returned the letter
to the Postal Service, where the dates April 2, 1993, and April
9, 1993, were written on the face of the notice of deficiency.
On April 2, 1993, a second yellow slip was prepared by a postal
clerk and given to the mail carrier for delivery to the Brownway
address. This second notice reminded petitioners that a
certified letter was waiting for them at the station and that it
would remain there, available for pickup, until April 9, 1993, at
which time it would be returned to the sender if not claimed.
The March 22, 1993, notice of deficiency was not claimed by
petitioners and was returned to the Internal Revenue Service
marked "unclaimed". The Internal Revenue Service received the
return envelope and its contents on April 16, 1993. The June 24,
1993, notice of deficiency underwent a similar process.
In compliance with Internal Revenue Manual provisions for
undelivered notices of deficiency, respondents' Examination
Support and Processing Branch (ESP Branch) places a returned
notice of deficiency in a taxpayer's administrative files. The
ESP Branch does not update respondent's computer system to
reflect a new address shown on a returned notice of deficiency
based on a handwritten address placed on the envelope, because
employees of the ESP Branch do not know who wrote the address on
the envelope. Since the Brownway address was handwritten on both
of petitioners' returned notices of deficiency, petitioners'
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