Daniel C. Noonan - Page 6

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               According to petitioner, he filed a 1988 Federal return in             
          March 1992 without payment of the tax liability shown thereon.              
          Petitioner has no proof of mailing to show that he filed a 1988             
          Federal return at that time.  The IRS has no record of receipt of           
          that return from petitioner.                                                
               In 1992, Carla Burton (Ms. Burton), a revenue officer at the           
          Oxnard district office, began a taxpayer delinquency                        
          investigation to secure a 1988 Federal income tax return from               
          petitioner.  According to Ms. Burton, if there is no return on              
          file, the usual procedure is to request an original return from             
          the taxpayer.  If the return subsequently submitted by the                  
          taxpayer is complete, the information appears accurate, and there           
          are original signatures on the return, the usual procedure is to            
          process the return by forwarding it to the teller function of the           
          IRS.  If the taxpayer advises her that a return has been filed,             
          she would then request a copy of the return so that she could               
          examine the return to determine if there is a mistake, such as a            
          discrepancy in the Social Security number, on the return.  The              
          copy would not be processed because it would not contain original           
          signatures.  Ms. Burton typically documents in her notes whether            
          she received an original return from the taxpayer.                          
               Ms. Burton attempted to secure the return from petitioner,             
          rather than Mrs. Noonan, because his address was contained in her           
          records. On May 20, 1992, Ms. Burton went to petitioner's                   

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