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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 she
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