Audrey Carlisle - Page 6




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          formatting and style of the message contained therein is likewise           
          different from her previous letters.                                        
               Petitioner further alleges that she called Ms. Murdock’s               
          office in January 1999 and was told that Ms. Murdock was no                 
          longer handling her case.  Petitioner claims that when she spoke            
          to the secretary who answered the phone, she identified herself             
          with her Social Security number and the Adele Street address.               
          Lastly, petitioner contends that since she received her tax                 
          booklet in early January at the Adele Street address, respondent            
          knew of this address before the notices of deficiency were issued           
          in February.                                                                
               Respondent contends that the notices of deficiency were sent           
          to petitioner’s last known address, and petitioner failed to                
          petition the Court within the statutory period.  Respondent                 
          argues that petitioner’s October 1998 and November 1998 letters             
          did not provide “clear and concise” notice of an address change.            
          Testimony of Mitchell Farah                                                 
               During the first hearing on this matter, the Court                     
          questioned how respondent was able to send the tax booklet for              
          1998 to petitioner’s Adele Street address.  Respondent                      
          subsequently moved to reopen the record to answer this concern              
          (which motion was granted), and a second hearing was held.                  
          Respondent called Mitchell Farah (Mr. Farah) as a witness.  Mr.             
          Farah is the manager of the mailouts and composition section of             






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