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the taxable years 1988, 1990, 1991 (the second notices of
deficiency). In the second notices of deficiency, respondent
determined the following deficiencies in petitioner's and Mrs.
Millsap's Federal income taxes and penalties and additions to
tax:
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6661 6662
1988 $13,554 --- $678 $3,389 ---
1990 2,728 $610 --- --- $531
1991 4,962 1,225 --- --- 992
The first notices of deficiency were sent by certified mail
and were addressed to petitioner at 14 Atteiram Drive, Rome,
Georgia 30161 (the Atteiram Drive address) and at 178 East 11th
Street, Rome, Georgia 30161 (the East 11th Street address). The
second notices of deficiency were also sent by certified mail and
were addressed to petitioner and Mrs. Millsap at the Atteiram
Drive address and at the East 11th Street address.
The notices of deficiency that were mailed to the East 11th
Street address were returned to respondent by the Postal Service
marked "attempted, not known, Rome, GA 30161". The notices of
deficiency that were mailed to the Atteiram Drive address were
not returned to respondent.
On April 19, 1993, prior to the mailing of the first and
second notices of deficiency, respondent sent petitioner a
"Notice of Jeopardy Assessment and Right of Appeal" for the
taxable years 1985, 1987, 1989, and 1991 (the first jeopardy
notice). On the following day, April 20, 1993, respondent sent
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