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petitioner and Mrs. Millsap a "Notice of Jeopardy Assessment and
Right of Appeal" for the taxable years 1988 and 1990 (the second
jeopardy notice).
Both the first and second jeopardy notices were sent by
certified mail and were addressed to petitioner and Mrs. Millsap
at the Atteiram Drive address. Both such notices were delivered
to, and receipted by, "Bertha Millsap" on April 24, 1993.
Petitioner and Mrs. Millsap filed joint Federal income tax
returns for 1989 and 1991 in January 1993. Both returns listed
the East 11th Street address as petitioner's and Mrs. Millsap's
home address.2
Petitioner did not file an income tax return for 1992.
In mailing the first and second notices of deficiency on
June 11, 1993, respondent utilized the East 11th Street address
because that was the address listed on petitioner's most recently
filed income tax returns. In mailing duplicate original notices,
respondent utilized the Atteiram Drive address because
respondent's agents, acting on information furnished by a third-
party earlier in the year, had actually observed petitioner at
2 Respondent's records indicate that petitioner did not
file an income tax return for 1990. However, petitioner attached
a copy of a purported joint return for that year to his Rule
50(c) statement. That copy, however, does not bear the signature
of either petitioner or Mrs. Millsap. In contrast, that copy
does bear a preparer's signature and the date of Aug. 14, 1991.
Further, that copy lists the East 11th Street address as
petitioner's and Mrs. Millsap's home address.
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