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June 30, 1992, explaining Sicari's obligations for filing Federal
tax returns, paying taxes, and paying Federal tax claims. Each
letter listed Sicari's name and address as it appeared on his
bankruptcy petition. On September 25, 1992, Special Procedures
filed with the Bankruptcy Court a Form 6338(C), Proof of Claim
for Internal Revenue Taxes (Bankruptcy Code Cases). The Form
6338(C) listed Sicari's name and address as it appeared on his
bankruptcy petition.
Internal Revenue Agent James Manico (Manico) reviewed the
subject notice of deficiency for technical and procedural
accuracy before it was issued. Manico has been a senior reviewer
for the Quality Measurement Staff in the Albany District Office
since August 1981. In order to determine petitioners' last known
address, Manico reviewed petitioners' administrative file and
instructed the statutory notice clerk in Albany to run a computer
search. Nothing in petitioners' administrative file alerted
Manico to an address change. On August 21, 1992, the statutory
notice clerk searched two different IRS computer databases, known
as the INOLE and the ENMOD, to ascertain petitioners' last known
address. The results of these two searches indicated that
petitioners' address was the Route 208 address, based on
petitioners' 1988 and 1989 returns. A subsequent search of the
INOLE database, conducted on October 1, 1992, indicated no change
in address.
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