Lester Johnson and Sherelle D. Brooks-Johnson - Page 5

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               Sometime before March 19, 1996, petitioners submitted to the           
          service center a Form 8821, Tax Information Authorization,                  
          regarding taxable years 1988 through 1994.  The form listed                 
          petitioners' address as the Grand Avenue address.  By letter                
          dated March 19, 1996, that form was returned to petitioners                 
          because it did not properly contain both petitioners’ signatures            
          and signature dates.                                                        
               Petitioner Sherelle D. Brooks-Johnson (Ms. Brooks-Johnson)             
          testified at the hearing in this matter.  While Mr. Johnson was             
          present in the courtroom and was invited by the Court to testify,           
          he declined.  Ms. Brooks-Johnson stated that petitioners had                
          lived at the Scenic Ridge address until March 1995, at which time           
          they moved to the Grand Avenue address.  The Diamond Bar address            
          was a second address that they used for business.  She further              
          stated that the audit of the 1993 return was ongoing at that time           
          and that she had given her new address to the examining agent.              
          Examination of the 1994 return was conducted by a different                 
          agent, but Ms. Brooks-Johnson stated that both agents were aware            
          of the two audits.  Neither of those agents was called as a                 
          witness.  The record is not clear as to whether or when such                
          notice of change of address was given to the agent examining                
          1993, and petitioners did not have any correspondence from him or           
          her before September 3, 1996.                                               







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