- 3 -
respondent determined deficiencies in and additions to
petitioners' Federal income taxes as follows:
Additions to Tax
Sec. Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6661 6653(a)(1)(A) 6653(a)(1)(B)
1983 $99,613 $4,981 1 $24,903 -- --
1984 38,967 1,948 1 9,742 -- --
1985 30,124 1,506 1 7,531 -- --
1986 42,014 -- -- 10,503.50 $2,101 1
1 50 percent of the interest due on the deficiencies.
On November 10, 1992, the notice of deficiency was returned
to the Examination Support and Processing unit of the Albany
District Office. The envelope bore a "Return to Sender" stamp-
mark in red ink, and the "REASON CHECKED" for return was
"Unclaimed".1 Also, the words "Return unclaimed" had been
handwritten at the top of the envelope by Marianne Walker
(Walker), the Postmaster for Gardiner, New York. Another stamp-
mark on the envelope listed "Name", "1st Notice", "2d Notice",
and "Return". The dates "9-24", "10-16", and "10-19" had been
handwritten next to "1st Notice", "2nd Notice" and "Return",
respectively.
Petitioners have resided in the same house in Gardiner, New
York, since approximately 1976. In each of the years 1991 and
1 "Unclaimed" was one of the options listed on the envelope as
available to explain why the letter was being "Returned to
Sender". The other options were: "Refused"; "Attempted-Not
Known"; "Insufficient Address"; "No such street [or] number"; "No
such office in state"; and "Do not remail in this envelope".
None of these other options had been checked off.
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