Fletcher H. Hyler - Page 4

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          filing penalty.  The IRS also abated $185.51 of the assessed                
          interest.  These abatements resulted in a credit of $1,304.16 in            
          favor of petitioner, which was applied to his outstanding                   
          liabilities for 1993.                                                       
               Revenue Agent Brian Rausch (Rausch) began an examination of            
          other aspects of petitioner’s 1995 income tax return on                     
          December 31, 1997.  Connie Stone (Stone), petitioner’s sister and           
          a resident of Virginia, represented petitioner.  Stone falsely              
          represented that she was licensed as a certified public                     
          accountant.  The examination focused on Schedule C, Profit or               
          Loss From Business, deductions claimed by petitioner.  During the           
          examination, Stone requested that petitioner’s address be changed           
          to her address in Henry, Virginia.  The IRS entered this change             
          into its records during the week of August 16, 1998.  On                    
          August 18, 1998, the IRS received petitioner’s 1997 Federal                 
          income tax return, which was timely filed pursuant to an                    
          extension of time.  This return bore the Woodside address.  Its             
          receipt caused the IRS again to change its records, during the              
          week of October 25, 1998, to reflect that petitioner’s address              
          was once again the Woodside address.                                        
               At the end of November 1998, petitioner moved from the                 
          Woodside address to Portola Valley, California.  He submitted a             
          mail forwarding request to the U.S. Postal Service reflecting his           

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