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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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