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88240 (the Hobbs address). Respondent did not post the Hobbs
address to respondent's computer records until December 25, 1995.
Petitioner did not receive the 30-day letter.
On March 29, 1996, the Austin Service Center mailed a notice
of deficiency to petitioner at both the Hobbs address and the
Albuquerque address. The notice of deficiency determined a
deficiency in petitioner's income tax and additions to tax in the
same amounts, and on the same basis, as proposed in the 30-day
letter. Thus, the notice of deficiency determined a deficiency
in petitioner's income tax for the taxable year 1993 in the
amount of $377,365 and additions to tax in the amounts of
$94,341.25 under section 6651(a) and $15,809.68 under section
6654(a).6
Petitioner received the notice of deficiency shortly after
it was mailed to her.7 Petitioner promptly contacted an IRS
representative at the "800" number set forth on the notice of
deficiency. Petitioner explained that the amounts reported on
the Forms 1099-G referred to a single debt owed by petitioner to
Moncor Bank and that such debt was discharged by the bankruptcy
6 The notice of deficiency also advised petitioner that she
was liable for interest (calculated through Dec. 20, 1995) in the
amount of $74,934. Thus, according to the notice, the total
amount due from petitioner (calculated through Dec. 20, 1995) was
$562,450.
7 Petitioner received the copy of the notice of deficiency
that was mailed to her at the Hobbs address. The other copy was
returned to respondent by the Postal Service as undeliverable.
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