Ronald Thomas - Page 3

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          redetermination of their tax liability for 1978.  At the time,              
          the Thomases continued to reside together at the Lightning View             
          address.  On November 30, 1983, the Court dismissed the Thomases'           
          petition on the ground that respondent had not issued a notice of           
          deficiency to the Thomases for 1978.                                        
               During the fall of 1983, petitioner and Shirley Thomas were            
          experiencing marital difficulties and decided to separate.  To              
          reduce the impact on his children, petitioner left the Lightning            
          View address.  By December 1983, petitioner had moved into an               
          apartment at 4016�, North Rogers Avenue, Baltimore, Maryland                
          21207 (the Rogers Avenue address).                                          
               On December 30, 1983, the Chief of the Collection Branch               
          assigned to the Internal Revenue Service Center in Philadelphia,            
          Pennsylvania, sent a Form 4901, Request for Information About Tax           
          Form, to petitioner at the Rogers Avenue address stating that               
          respondent had no record of receiving his 1982 tax return.  The             
          record does not clearly reflect how the Collection Branch became            
          aware of petitioner's Rogers Avenue address.                                
          On January 30, 1984, the Internal Revenue Service District                  
          Director in Baltimore, Maryland, mailed a joint notice of                   
          deficiency to the Thomases determining a deficiency of $36,401.86           
          in their Federal income tax for 1978 and an addition to tax under           
          section 6651(a) in the amount of $9,592.40.  The notice, which              
          was mailed by certified mail to the Lightning View address, was             





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