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Respondent mailed petitioner a 30-day letter on February 1,
1994. The 30-day letter was mailed to 5808 Franklin St., Denver,
CO 80216 (the Denver Address). It is not clear where respondent
obtained this address. Regardless, the letter was returned to
respondent by the Postal Service bearing the notations "no
forward order on file", "unable to forward", and "returned to
sender".
In addition, respondent sent five different Forms 4759
(Address Information Request) to the postmasters in Denver,
Colorado, Nathrop, Colorado, and Colorado Springs, Colorado, to
verify five possible addresses of petitioner. None of the
possible addresses were confirmed as petitioner's then current
address. Respondent also contacted petitioner's parents to
ascertain petitioner's correct address. Petitioner's parents
informed respondent that they did not have such information.
Apparently, petitioner moved to a new address, 2200 S. Rock
Road, Apt. 1016, Wichita, Kansas 67207 (the Kansas Address)
sometime in 1993 or 1994. Petitioner did not file Form 8822
(Change of Address) to inform respondent of a new address.
Further, by August 1994, petitioner had not filed another tax
return, and the 1986 return remained as petitioner's most
recently filed return.
By notice dated August 24, 1994, respondent's district
office in Denver, Colorado, determined deficiencies in, and
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