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Petitioners jointly filed a Form 1040, U.S. Individual
Income Tax Return, for each of the years 1983 through 1986. On
May 14, 1991, petitioners filed a Form 1040-X, Amended U.S.
Individual Income Tax Return, for taxable year 1986. On their
1983 and 1984 returns, petitioners listed their address as Route
508, Gardiner, NY 12525. On their 1985 and 1986 returns, and on
their 1986 amended return, petitioners listed their address as
the Route 208 address. The record does not include petitioners'
tax returns for the years 1987 through 1990. Prior to issuance
of the notice of deficiency in this case, respondent had not yet
received petitioners' returns for 1990 and 1991. Petitioners did
not file a tax return for 1991 until 1995.
On June 9, 1992, petitioner Anthony Sicari (Sicari) filed a
voluntary petition in bankruptcy with the U.S. Bankruptcy Court
in the Southern District of New York. In his bankruptcy
petition, Sicari listed his name and address as "Anthony Sicari
a/k/a Anthony Salerno, Route 208, Box 1370, Gardiner, NY 12525."
The Special Procedures function of the Collection Division of the
Albany District Office of the IRS received notice of the
bankruptcy proceedings. Special Procedures files proofs of claim
and establishes and maintains case files for bankruptcy
proceedings, inter alia. Using the information in the bankruptcy
petition, Special Procedures created a file on Sicari on its
computer database, the Automated Insolvency System (AIS).
Special Procedures mailed to petitioners two letters, each dated
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