Audrey Carlisle - Page 3




                                        - 3 -                                         
               Before September 1998, petitioner resided at 7500 Crescent             
          Avenue, Apartment 125, Buena Park, California (the Crescent                 
          Avenue address), which was her brother’s residence.  The Crescent           
          Avenue address was the address on petitioner’s 1997 Federal                 
          income tax return filed in 1998.  By letter dated September 19,             
          1998, petitioner informed the IRS that she had moved to 370 North           
          Oak Street, Orange, California (the Oak Street address).1                   
          Respondent made this address change in the IRS taxpayer address             
          database.                                                                   
               On October 26, 1998, respondent received a letter from                 
          petitioner dated October 16, 1998.2  The letterhead of this                 
          letter reflects petitioner’s address as 130 West Adele Street,              
          Apartment F, Anaheim, California (the Adele Street address).                
          There is no statement in petitioner’s letter that there was a               
          change of address.  Respondent did not make an address change in            
          the database for petitioner’s address.  On November 12, 1998, Ms.           
          Murdock received another letter3 from petitioner dated                      
          October 29, 1998, which also reflects the Adele Street address in           



               1  Petitioner sent this letter to the IRS Service Center in            
          Fresno, California, and it was transferred to Ms. Murdock.                  
               2  This letter was also sent to the Service Center in                  
          Fresno, California, and refers to petitioner’s disagreement with            
          the changes proposed by respondent.                                         
               3  In this letter, petitioner states her disagreement with             
          the examination report.                                                     





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