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or any notices of delivery of certified mail from the IRS after
the March 5 letter.
The notice of deficiency had been prepared and mailed by IRS
employee Janet Mak. Before Ms. Mak mailed the notice of
deficiency, she verified petitioners’ mailing address by
examining addresses of correspondence in the administrative file
and by checking the Integrated Data Retrieval System (IDRS), a
computer database used by the IRS. Ms. Mak was not aware of any
other computer systems maintained by the IRS that would contain
petitioners’ address. Further, IDRS was the only system to which
she had access. If the address in the file and the address in
IDRS were different, it was Ms. Mak’s procedure to send a notice
to each address. When Ms. Mak prepared the notice of deficiency,
the administrative file contained copies of the documents that
had been sent by certified mail to, and claimed and received by,
petitioners at the Box 227 address in January and February 1996.
Moreover, when Ms. Mak prepared the notice of deficiency, IDRS
showed the Box 227 address as petitioners’ address. Ms. Mak was
not aware of the existence of the March 5 letter or the Form 2848
when she determined where to mail the notice of deficiency.
The IRS received the unclaimed envelope containing the
notice of deficiency on May 28. When Ms. Mak received the
unclaimed envelope, she checked IDRS, and it showed a different
address; namely, petitioners’ street address, 772 Indian Neck
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Last modified: May 25, 2011