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petitioner for his cooperation. The letter was signed by Derome
Bratvold, Chief, Adjustments Branch. This was the first response
petitioner received from respondent. Petitioner was not sure
what year or what issues the September 21, 1999, letter regarded.
Petitioner, however, believed that this letter was in response to
his concerns regarding filing his 1999 income tax return.
In a November 16, 2000, letter from the IRS, mailed to
petitioner in Soledad, California, the IRS thanked petitioner for
his interest in paying his delinquent taxes and for submitting a
financial statement Form 433-F, Collection Information Statement.
The letter referenced petitioner’s 1997 tax year, acknowledged
that petitioner was in State prison, apologized for any
inconvenience the IRS caused petitioner, and thanked him for his
cooperation. This letter was signed by M. Brown, Chief, Accounts
Management Branch 2.
Petitioner never contacted respondent to specifically direct
respondent to use a different address than the L.A. address. On
July 26, 2001, however, respondent mailed petitioner a notice of
deficiency for 1998 to his prison address.
On November 28, 2001, petitioner filed a petition with the
Court disputing respondent’s determinations for 1997 and 1998.2
2 The envelope containing the petition bears a postmark of
Oct. 2, 2001. We have previously noted that during this time
period the Court was experiencing significant anthrax-related
mail delays. Gibson v. Commissioner, T.C. Memo. 2002-218.
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