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The Office of the Taxpayer Advocate also requested suspension of
collection activities during the consideration of petitioner’s
administrative claim, and the IRS did not undertake collection
activities while petitioner’s claim was pending.
In the Seattle Appeals Office, petitioner’s claim was
assigned for review to Special Procedures Advisor Jill Pace
(Pace), who received it on August 6, 1999. On August 11, 1999,
Pace sent to petitioner a form letter regarding the possibility
of third-party contacts; her letter was sent to the Portola
Valley address that was on petitioner’s damages claim. Pace did
not check IRS records to determine an alternate address for
petitioner, and she was unaware that the address used by
petitioner on the administrative claim was a new address. During
her review of the administrative claim, Pace met with petitioner
and Stone. Neither petitioner nor Stone informed Pace of
petitioner’s change of address the previous November. Petitioner
did, however, provide a Form 2848, Power of Attorney and
Declaration of Representative, appointing Stone as his
representative for multiple income tax periods including 1993,
1995, and 1997.
On December 28, 1999, the holder of a deed of trust on
petitioner’s residence commenced a nonjudicial foreclosure
proceeding with the filing of a Notice of Default and Election to
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