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because he "was spending a lot of time in California"
and "was intending to move there".
In the case of his 1990 return, petitioner testified
that he prepared this return approximately 10 days after
he prepared his 1989 return. The address listed on
petitioner's 1990 return is 7 Baldwin Hill Place,
Morristown, New Jersey 08057.
Petitioner testified that he gave his 1990 return to
the revenue agent who was auditing his 1988 return "and
mailed a copy". Petitioner's testimony regarding the
filing of his 1990 return also includes the following:
Q And for the 1990 return, you prepared that in
New Jersey, as well, correct?
A The actual return, yes.
Q And you mailed that in New Jersey, correct?
A My recollection is I gave this directly to
Mr. Brokowski [i.e., the revenue agent] in New
Jersey.
Q So you're saying, then, for 1990, that you never
filed a return without giving one to Brokowski
first. You never filed one independently for
1990.
A I think I mailed it in, as well, but I gave
him a copy. I gave two-–I think I gave him the
original and mailed a copy, it is my
recollection.
Q Would you mail a copy of a 1040 to a Service
Center? Why?
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