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On or about November 20, 1995, respondent's service center
in Austin, Texas (the Austin service center) sent a 30-day letter
to petitioner (the 30-day letter). The 30-day letter stated that
respondent had no record of receiving an income tax return from
petitioner for the taxable year 1993. The 30-day letter then
proposed a deficiency in petitioner's income tax and additions to
tax for 1993 based on income reported to respondent by third
parties. Such income included discharge-of-indebtedness income
in the amount of $1,004,812, i.e., the sum of the amounts
appearing on the information returns as set forth above.4 The
30-day letter stated that petitioner could appeal "the proposed
assessment" to the IRS Appeals Office.
The 30-day letter was mailed to petitioner at her former
address in Albuquerque, New Mexico (the Albuquerque address).5
The Albuquerque address was petitioner's address as it appeared
in respondent's computer records at the time that the 30-day
letter was sent (i.e., on or about November 20, 1995). Prior
thereto, on October 23, 1995, petitioner filed a Federal income
tax return for the taxable year 1994. Petitioner listed her
address on her 1994 return as P.O. Box 405, Hobbs, New Mexico
4 The proposed deficiency was also based on $5,003 of
unreported interest, dividends, and gain from the sale of
securities. A single individual having only such amount of
income in 1993 was not required to file an income tax return for
that year. Sec. 6012(a)(1).
5 Petitioner moved from the Albuquerque address in June
1993.
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