Keith Lee Wilson - Page 4

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               Respondent later mailed by certified mail a notice of                   
          deficiency for 1988, 1992, and 1993 to petitioner at 705 El Medio            
          on July 8, 1996, and petitioner received that notice of                      
          deficiency in a timely fashion.  The petition herein is timely               
          with respect to that notice of deficiency.                                   
               The envelope in which the subject notice of deficiency was              
          mailed by respondent was received in evidence.  It is a standard             
          business-sized window envelope.  Across the window was a                     
          scrawling apparently made by a felt-tip pen.  Above the window in            
          blue ballpoint pen are the numbers “705”.  On the right-hand side            
          of the envelope is a stamp providing for entries on four lines               
          identified as “Name”, “First Notice”, “Second Notice”, and                   
          “Return”.  Entries on or near these four lines are respectively              
          “MLJ”, “6-5-96", “6-10", and “6-20".  In addition, the envelope              
          bears the stamps “unclaimed” and “return to sender” and                      
          indications that the envelope was received by the Los Angeles                
          District of the Internal Revenue Service on June 25, 1996, and by            
          suspense control of Internal Revenue Service on July 3, 1996.                
               Respondent presented the testimony of Anthony Ficklin (Mr.              
          Ficklin), a delivery supervisor of the U.S. Postal Service, who              
          had been in that position approximately 8 to 9 years and had been            
          at the branch of the Pacific Palisades, California, post office              
          handling petitioner’s mail delivery for about 5 years.  Mr.                  
          Ficklin was familiar with the procedures for handling certified              





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