Carolyn S. Eifert, A/K/A Sue Armstrong - Page 7

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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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