Nicholas O. Bachynsky - Page 3

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               2)   7530 Regency Square                                               
                    Houston, Texas 77036                                              
               Respondent concedes that the second address is not                     
          petitioner's last known address, and we will not make any further           
          reference to it.                                                            
               "FCI Three Rivers" refers to the Federal Correctional                  
          Institution located in Three Rivers, Texas.  The notice of                  
          deficiency respondent mailed to petitioner at the Federal                   
          Correctional Institution was not stamped with a date.  However,             
          U.S. Postal Service Form 3877 indicates that a notice of                    
          deficiency for taxable year 1988, bearing petitioner's Federal              
          inmate registration number of 47424-079, was sent by certified              
          mail from the Internal Revenue Service, District Director,                  
          Houston, Texas, to petitioner at "FCI Three Rivers, P.O. Box 400,           
          Three Rivers, Texas 78071" on November 3, 1995.  The certified              
          mail number of the notice of deficiency was 15045.  The Postal              
          Service Form 3877 was postmarked November 3, 1995, and was                  
          initialed by the receiving Postal Service employee who filled in            
          the total number of items received.                                         
               Petitioner filed a petition with the Court on March 14,                
          1996.  The petition was mailed in an envelope bearing a return              
          address of a Houston law firm and a private postage meter                   
          postmark.  The postmark does not contain a date.  March 14, 1996,           
          is 132 days after the date the notice of deficiency was mailed.             

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