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about September 28, 1993. Later, Price attempted to expand that
examination to include the years in issue. On several occasions
during the course of Price’s examination, she visited offices of
petitioner at 6019 Tower Court, Alexandria, Virginia. Price’s
examination of petitioner was closed on or about August 1, 1994,
with respect to the years in issue. Thereafter, a notice of
deficiency with respect to the years in issue was prepared by or
under the supervision of John Henry, Senior Reviewer, Quality
Assurance Branch, Richmond District, Internal Revenue Service,
Richmond, Virginia. On October 6, 1994, three copies of that
notice of deficiency (the October 6 notice) were sent by
certified mail, addressed as follows:
(1) St. Joseph Lease Capital Corporation
Post Office Box 19307
Alexandria, Virginia 22320
(2) St. Joseph Lease Capital Corporation
6019 Tower Court
Alexandria, Virginia 22320
(3) Roger A. Pies, Esquire
Suite 800 South
601 Thirteenth Street, N.W.
Washington D.C. 20005
The first address resulted from a query to the main Internal
Revenue Service computer. The second address was found in the
case file and is the address at which Price carried out a portion
of her examination. Roger A. Pies (Pies) is an attorney who
represented petitioner during the course of Price’s examination,
and the third address is that of Pies.
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