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address. The letter requested that petitioner contact respondent
to arrange a conference and also requested substantiation of
petitioner’s claimed deductions.1
Petitioner asserts that on May 28, 1996, he faxed to
respondent a letter informing respondent that he had moved to
Beijing, China. Respondent claims that he did not receive this
letter.
On May 29, 1996 respondent mailed a 30-day letter to both
the Atherton and Millbrae addresses. This letter proposed
adjustments to petitioner’s 1993 and 1994 tax returns and
indicated that petitioner could request an Appeals Office
conference.
On July 15, 1996, respondent’s auditors sent petitioner’s
1993 and 1994 administrative files to the Examination Support
Procedure (ESP) unit for the preparation of a notice of
1 Respondent alleges that on Mar. 26, 1996, respondent sent a
letter to petitioner at both the Atherton and Millbrae addresses
indicating that respondent had opened an audit for the 1993 tax
year. According to respondent, the audit letter requested that
petitioner contact respondent to arrange a conference and to
provide information concerning petitioner’s claimed deductions.
Respondent also states that the audit letter that was sent to the
Atherton address was returned as undeliverable and that the U.S.
Postal Service attached to the letter a mailing label that
indicated that petitioner’s new address was the Millbrae address.
Respondent also claims that the U.S. Postal Service did not
return the letter that was sent to the Millbrae address. These
allegations are supported by the affidavit of Barbara Gee,
manager of the Office Audit Section of the San Mateo Office of
the IRS. Copies of the documents Ms. Gee refers to are not
included in the record.
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