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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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