Ronald Thomas - Page 4

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          returned to respondent marked "Unclaimed".  Shirley Thomas was              
          residing at the Lightning View address throughout the period in             
          question.  The record indicates that the notice of deficiency was           
          mailed to the Lightning View address on the basis of information            
          contained in the Thomases' administrative file and that                     
          respondent did not conduct a computer search for petitioner's               
          address before mailing the notice of deficiency.  The record does           
          not reflect whether respondent made any further efforts to                  
          deliver the notice of deficiency to the Thomases immediately                
          after the original notice was returned undelivered.2                        
               Between 1982 and 1984, the Thomases were contacted by                  
          various revenue officers concerning the collection of Delafield's           
          unpaid Federal employment taxes and the possible imposition of              
          the 100-percent penalty against the Thomases with respect to                
          those taxes.  Sec. 6672.  Revenue Officer James Land met                    
          petitioner during a field visit to Delafield's McDonald's                   
          restaurant in Baltimore.3  In July 1982, Revenue Officer Grace              
          Jaecksch prepared a Form 4180, Report of Interview Held With                
          Persons Relative to Recommendation of 100-Percent Penalty                   
          Assessments, based upon an interview with Shirley Thomas.  On               
          April 19, 1984, Revenue Officer Carla Mims-Dixon met with Mrs.              


          2  The Commissioner destroyed the Thomases' administrative                  
          file in the normal course of business.                                      
          3  The record does not reflect the date of this visit.                      




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