James A. and Muriel M. Andrews - Page 7

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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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