Michael P. and Dolores A. Gam - Page 4




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          delivery, nor does it have any record of article returned for a               
          certified letter mailed by respondent on October 22, 1997, to                 
          petitioners’ correct address.                                                 
               On or before June 29, 1997, petitioners received from                    
          respondent a Form CP-2000, dated June 25, 1997, proposing a 1995              
          deficiency in the amount of $4,625, and asking petitioners to                 
          respond within 30 days.  This letter was addressed to petitioners             
          at the 12-digit ZIP Code address.                                             
               On May 17, 1998, petitioners received a letter dated May 13,             
          1998, from respondent’s Taxpayer Advocate addressed to the 12-                
          digit ZIP Code address.  This letter included a copy of the                   
          original notice of deficiency, part of which petitioners attached             
          to the petition filed in the instant case.  This was the first                
          time petitioners received a copy of the notice of deficiency.                 
               The petition in the instant case was filed on July 24, 1998,             
          which is 275 days after October 22, 1997, when the notice of                  
          deficiency was mailed.  The envelope in which the petition was                
          sent to this Court is postmarked July 22, 1998, which is 273 days             
          after the notice of deficiency was mailed.                                    
               The correct ZIP Code for the address 25521 La Mirada, Laguna             
          Hills, California, is not the 12-digit ZIP Code.  There is no                 
          such ZIP Code as the 12-digit ZIP Code within the USPS system.                
          The correct ZIP Code for 25521 La Mirada, Laguna Hills,                       
          California, is 92653-5316--the 9-digit ZIP Code address.                      






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