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regarding respondent's examination of petitioners' 1990 income
tax return. During this period, respondent addressed all
correspondence to petitioners at the Georgia address.
In August 1993, petitioners' case was transferred to
Appeals Officer Kay Strain in Atlanta, Georgia. On October 2,
1993, Betty Richardson Stafford (petitioner) advised Appeals
Officer Strain in a telephone conversation that she (i.e.,
petitioner) had separated from petitioner John Stafford, but
that she would continue to reside at the Georgia address.
Appeals Officer Strain did not attempt to ascertain John
Stafford's new address, nor did petitioner offer such
information.
John Stafford resided in Brooklyn, New York, from November
1993 to November 1994. He did not notify respondent of his
change of address.
In the meantime, on March 21, 1994, petitioners filed an
amended joint income tax return for 1990. On their amended
return, they listed the Georgia address as their address.2 On
July 25, 1994, and in response to receiving the amended 1990
return, respondent issued a statement of change of account to
2 The Georgia address also appears on petitioners' joint
income tax return for 1992, which was filed Apr. 26, 1993, and on
petitioner's individual income tax return for 1993, which was
filed Feb. 7, 1994. The record indicates that petitioner John
Stafford failed to file an income tax return for 1993.
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