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except as to certain matters directly bearing on the issue of
actual delivery.
On October 9, 1992, respondent issued to petitioners by
certified mail, return receipt requested, a statutory notice of
deficiency (the statutory notice) addressed as follows: Mr.
Anthony Sicari and Mrs. Esther Sicari, Route 208, Gardiner, NY
12525 (the route 208 address).
During 1992, the Postal Service had changed petitioners'
permanent mailing address to the following address: 871 Route
208, Gardiner, NY 12525. Early in 1992, the postmaster of
Gardiner, New York, Marianne Walker (Walker), issued notices
explaining the address changes and notifying Gardiner Postal
Service customers that regardless of the changes, all mail would
be delivered without interruption. In fact, the Gardiner Postal
Service delivered mail to customers even if it was addressed to
the route 208 address throughout 1992 and up to the time of
trial. In October 1992, the Postal Service treated mail
addressed to the route 208 address as properly addressed.
In 1992, Theresa Williams (Williams) was the letter carrier
for the postal route that includes route 208 and the Sicari
residence. She worked throughout the month of October 1992
without missing a day for sick leave or vacation. She was well
acquainted with the location of the Sicari residence. During
1992, if items of certified mail were addressed to petitioners at
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