- 7 - 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, andPage: Previous 1 2 3 4 5 6 7 8 9 Next
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