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does not enter any address information received in this manner on
any of his databases; and
(4) if no remittance accompanies the request, the request is
filed and subsequently destroyed by respondent 1 year after the
end of the processing year.
See Internal Revenue Manual sec. 512(12)(2)(g); Internal Revenue
Manual Handbook, sec. 1(15)59.26 at par. 68.
Except for the requests for extension, respondent did not
receive any correspondence from petitioner prior to the mailing
of the notice of deficiency. Further, prior to the mailing of
the notice of deficiency, no division of the Internal Revenue
Service had ever corresponded with petitioner at the Kansas
address.
Respondent received two Forms 1099-MISC with respect to
petitioner from a third-party employer bearing the Kansas
Address. Respondent's records reflect that these information
returns were received by respondent in 1995 and were issued in
respect of the taxable year 1994.
About 3 years after the notice of deficiency was mailed,
respondent mailed a copy of a notice of Federal tax lien to
petitioner in September 1997, at the Kansas Address. Petitioner
mailed his petition for redetermination to the Court in an
envelope bearing a private postmeter postmark date of October 31,
1997. The petition was filed by the Court on November 3, 1997.
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