Michael B. and Diana C. Wheeler - Page 4




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          names.  The copy of the notice placed in evidence by respondent             
          only lists Mr. Wheeler's name.  Respondent asserts that Mrs.                
          Wheeler's name was not listed on the notice mailed to the El Jer            
          address and that her name was added sometime after the notice was           
          mailed.  Mrs. Wheeler's name as it appears on the copy of the               
          notice presented by petitioners does appear to have been added              
          after the initial text was drafted.  Mrs. Wheeler's name on                 
          petitioners' copy is typed in a different font from the rest of             
          the text.  Petitioners do not contest respondent's assertion that           
          Mrs. Wheeler's name apparently was added after the notice of                
          deficiency had been prepared.  Instead, petitioners claim that              
          Mrs. Wheeler's name was added by respondent before the notice was           
          mailed.                                                                     
               Based upon this record, we find that the notice was not                
          issued to Mrs. Wheeler.  Michael Meyering (Mr. Meyering), an                
          agent in respondent's examination review staff, was assigned to             
          work on a case regarding Mr. Wheeler for the years 1992 through             
          1996.  Mr. Meyering was not assigned to work on a case regarding            
          Mrs. Wheeler.  Upon completion of the audit, Mr. Meyering                   
          prepared duplicate statutory notices of deficiency in the name of           
          Mr. Wheeler.  Mr. Meyering did not prepare a joint notice for Mr.           
          and Mrs. Wheeler.  A certified mailing list introduced by                   
          respondent verifies that duplicate originals of the notice were             
          issued to Mr. Wheeler.  The certified mailing list does not                 






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