Theolia Millsap - Page 6

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                  In a subsequent document filed with the Court, petitioner                             
            admitted that he was living at the Atteiram Drive address on June                           
            11, 1993, but that he did not receive any notice of deficiency at                           
            that address.  Petitioner stated further that he had moved from                             
            the East 11th Street address in 1989 and that his last known                                
            address was "114 Nourcross Way, Rome, Georgia".4                                            
            This matter was called for hearing at the Court's motions                                   
            session in Washington, D.C., on April 8, 1998.  Counsel for                                 
            respondent appeared at the hearing and presented argument and                               
            exhibits in support of the pending motion.                                                  
                  Petitioner did not appear at the hearing on April 8, 1998.                            
            However, he did file a Rule 50(c) statement, attached to which                              
            were "some copies of my tax."  These documents include copies of:                           
            Purported Federal and State corporate income tax returns for                                
            petitioner's company Millsap Construction for 1990, purported                               
            Federal and State income tax returns for petitioner and Mrs.                                
            Millsap for 1990 (see supra note 2), the Federal income tax                                 
            return for petitioner and Mrs. Millsap for 1991 (see supra p. 4),                           

                  4  The 1994 edition of Publication 65, the National Five-                             
            Digit ZIP Code and Post Office Directory, published by the U.S.                             
            Postal Service does not list any "Nourcross Way" in Rome,                                   
            Georgia.  There is, however, a "Norcross Way" in Rome, Georgia                              
            30165.  We note that documents pertaining to the 1989 taxable                               
            year that were attached to petitioner's Rule 50(c) statement,                               
            viz, Forms 1099-MISC purportedly issued by Millsap Construction,                            
            repeatedly reference "114 N. Crossway St., Rome, GA 30161".  The                            
            ZIP Code directory does not list "N. Crossway" or "Crossway" in                             
            Rome, Georgia.                                                                              

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