- 15 - curious that he did not notify the agent directly, as provided for in Rev. Proc. 90-18, supra. Instead, his letter was addressed to the district director and did not mention either the examining agent’s name or the fact that petitioners were currently under audit. More problematic is the simultaneous submission to the service center of mutually contradictory instructions regarding the address to which correspondence should be sent, when the pendency of a notice of deficiency was known to petitioners and Mr. Bezkorowajny. The fact that the correspondence provisions of the power of attorney form were specifically altered to request that correspondence be sent to petitioners at the Box 227 address, while an accompanying letter of the same date was drafted to direct that correspondence be sent to the Braun Co. address, leads us to conclude that the address instructions were in patent conflict. In a similar vein, petitioners have offered no explanation of their failure to respond to respondent’s March 13 letter seeking clarification of their intentions regarding an address change. We also note that approximately 1 month after respondent sought this clarification, petitioners filed their 1995 return and left the address section thereon blank. We believe it was at least foreseeable by petitioners and Mr. Bezkorowajny that their March 5 submissions would result in confusion regarding the address to which they wished the noticePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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