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1992 taxable year. Petitioners and Mr. Bezkorowajny also were
aware that the 3-year period of limitations with respect to the
1992 taxable year would shortly expire.4
On March 5, 1996, slightly less than a month before the
mailing of the notice of deficiency, Mr. Bezkorowajny hand-
delivered two documents to the IRS Taxpayer Service Center on
Fulton Street in Brooklyn, New York. The first document was a
letter, over Mr. Bezkorowajny’s signature, requesting certain
publications and a transcript of petitioners’ account and asking
the following:
Could you send this information to them [i.e.,
petitioners] and all future mail as soon as possible at
the current address of: James A. & Muriel M. Andrews
c\o G. Braun Oyster Co. P.O. Box 971 Cutchogue, N.Y.
11935 [the Braun Co. address].
As previously noted, the Braun Co. address is the mailing address
for petitioner’s place of employment. The letter was addressed
to the “District Director” and did not contain the examining
agent’s name or advise that petitioners were currently under
audit, stating instead that “My client is trying to determine his
tax and * * * needs a transcript of his account for the year
1992.” The second document, attached to the letter, was a Form
4 In January 1996, respondent sought petitioners’ consent to
extend the period of limitations for 1992, advising in a letter
that it would expire soon. Petitioners responded that same month
by seeking to narrow the scope of the consent. There is no
evidence in the record that petitioners ever consented to an
extension, and they allege in the petition that the 3-year period
of limitations expired on or about Apr. 15, 1996.
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