- 6 - April 1994 and that he notified respondent of this change of address. Petitioner claims that he was aware of audit activity with respect to his taxes for the years in issue and later received a so-called 30-day letter concerning the possibility of an Appeals Office conference. He claims that he called respondent's offices at least six times between May 18 and June 20, 1995, that he spoke with IRS personnel by telephone several times during that period, and that during those telephone conversations he notified respondent's representatives of his change of address. Petitioner presented a chart describing the time and subject matter of the alleged telephone conversations. Petitioner prepared the chart himself. He attached to it a telecommunications expense report, allegedly from the records of his employer, to demonstrate that several of the calls had been made. Respondent disputed the authenticity of the report and the accuracy of the chart. Petitioner failed to present any substantiating witnesses or other evidence. Petitioner failed to establish notice of change of address as a result of the alleged telephone conversations. Petitioner offered in evidence a series of letters dated between April 12, 1994, and February 9, 1995, addressed to IRS personnel and bearing the return address of 13 Skylark Drive. In several of these documents, petitioner purports to advise respondent of his change of address. Respondent asserts that shePage: Previous 1 2 3 4 5 6 7 8 9 Next
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