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contrary, the person to whom he spoke, Janet Cole, from the Los
Angeles Appeals Office, recalls the conversation but does not
recall receiving any added information as to petitioners’ new
address. The Appeals documentary record in the case, attached to
the supplement to respondent’s motion to dismiss for lack of
jurisdiction, reflects that an entry was made at some
undetermined time, changing the Fern Point Circle address to the
Blake Road address.
Moreover, in March 1996, petitioner husband filed a
voluntary petition in bankruptcy in the U.S. Bankruptcy Court for
the Eastern District of California, Sacramento Division, in which
he listed the Blake Road address as his current address.
If the Blake Road address was not petitioners’ last known
address, then certainly the Airway Avenue address for Mr.
Christensen would have been petitioners’ last known address. See
Honts v. Commissioner, supra. The record is clear that
respondent mailed by regular mail a copy of the notice of
deficiency for 1992 to Mr. Christensen on October 16, 1996, and
that he received it. Petitioners contend that respondent has
failed to prove the exact date upon which Mr. Christensen
received it, but we do not believe that is necessary. Respondent
did offer testimony of a representative of the U.S. Postal
Service that mail from respondent’s office to Mr. Christensen’s
office would normally have been received within 2 or 3 days, and
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