Charles R. Godwin et al. - Page 11

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          respondent sent Mrs. Godwin by certified mail a notice of                   
          determination under section 6330 (the Linda Godwin notice).  In             
          the section 6330 cases, petitioner filed a petition for                     
          redetermination on September 10, 2001, and both petitioners filed           
          a petition for redetermination on September 13, 2002.4                      
               On November 9, 2001, respondent sent petitioners by                    
          certified mail a notice of deficiency for their 1997 tax year for           
          a deficiency attributable to the disallowance of claimed casualty           
          losses from the 1997 earthquakes, Hurricane Danny, and Hurricane            
          Georges and for a section 6651(a)(1) addition to tax.  On January           
          7, 2002, petitioners filed a joint petition for redetermination             
          in the deficiency case.                                                     
               The section 6654(a) and 6651(a)(1) and (2) additions to tax            
          in the section 6330 cases and the section 6651(a)(1) addition to            
          tax in the deficiency case are now in dispute.                              
               Our ultimate finding, notwithstanding the natural disasters            
          and the changes in clerical and bookkeeping personnel at                    
          petitioner’s law office, is that petitioners did not exercise due           

               4Respondent moved to dismiss for lack of jurisdiction as to            
          Mrs. Godwin under docket No. 11382-01L because of issues                    
          regarding petitioner’s authority to represent her.  We granted              
          respondent’s motion, which was thereafter rendered moot by                  
          petitioner’s admission to practice before this Court, and                   
          respondent’s sending Mrs. Godwin a notice of determination under            
          sec. 6330, in response to which petitioner filed a petition with            
          the Court on behalf of Mrs. Godwin in docket No. 14817-02L.                 

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