Theolia Millsap - Page 5

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            that address.  Moreover, respondent's collection officer and                                
            other agents had executed a writ of entry at the Atteiram Drive                             
            address on April 19, 1993, and Mrs. Millsap was present at such                             
                  In October 1993, respondent's collection officer seized an                            
            automobile operated by Mrs. Millsap.  At the time of the seizure,                           
            which occurred on the premises of Mrs. Millsap's employer in                                
            Rome, Georgia, the collection officer first learned that Mrs.                               
            Millsap and/or petitioner had purportedly moved to 12 Landrum                               
            Place, Rome, Georgia 30161 (the Landrum Place address).                                     
                  Petitioner filed a petition for redetermination with the                              
            Court on October 3, 1997.3  The petition arrived at the Court in                            
            an envelope bearing a U.S. Postal Service postmark date of                                  
            September 29, 1997.                                                                         
            As indicated, respondent filed a Motion to Dismiss for Lack                                 
            of Jurisdiction on the ground that the petition was not timely                              
            filed.  Petitioner filed an Objection to respondent's motion in                             
            which he stated that he had moved in June 1993 from the Atteiram                            
            Drive address to the Landrum Place address and did not receive                              
            any notice of deficiency.  In his objection, petitioner also                                
            stated that respondent's collection officer knew of the change of                           
            address because the officer had seized Mrs. Millsap's automobile.                           

                  3  At the time that the petition was filed, petitioner                                
            resided in Atlanta, Georgia.                                                                

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