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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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