Ralph M. and Rosemary L. Conlon - Page 4

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          representative.  Mr. Mark had been petitioners’ accountant for              
          approximately 25 years.  The Form 2848 was signed by petitioners            
          and Mr. Mark and dated October 6, 1993.  The Form 2848 provided             
          that “Notices and other written communications will be sent to              
          the first representative listed in line 2.”  Mr. Mark was the               
          first, and only, representative listed in line 2.                           
               During October 1993, petitioners moved to Wellington,                  
          Nevada.  Petitioners did not notify respondent of their new                 
          address prior to August 26, 1994.                                           
               On August 26, 1994, respondent sent a notice of deficiency             
          to petitioners at the Sand Canyon Road address.  On that same               
          date, a copy of the notice of deficiency was sent to Mr. Mark.              
          In the notice, respondent determined a deficiency in petitioners’           
          income tax and an accuracy-related penalty for the taxable year             
          1991 in the amounts of $8,026 and $533.60, respectively.                    
          Petitioners did not receive the notice of deficiency; in                    
          contrast, Mr. Mark received the copy that was sent to him.                  
               On November 3, 1994, Mr. Mark prepared petitioners’ 1993 tax           
          return using their Wellington, Nevada, address.                             
               After the notice of deficiency was issued, but prior to the            
          end of the 90-day period in which petitioners could file a                  
          petition with this Court, Mr. Mark contacted respondent’s                   
          Examination Division on several occasions with respect to                   
          respondent’s deficiency determination.  Thus, on November 1,                

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