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FINDINGS OF FACT
The parties have stipulated most of the facts, which we
incorporate herein by this reference. When petitioner filed his
petition, he resided in Hamilton, Ohio.
A. 1990 Notice of Deficiency
Petitioner filed no tax return for the 1990 tax year. On
November 25, 1992, respondent mailed to petitioner a notice of
deficiency in regard to his 1990 income tax. Respondent mailed
the notice to 2325 Anderson Road, Apartment 240, Crescent
Springs, Kentucky (the Kentucky address). This was the address
listed on petitioner’s 1988 Federal income tax return, his then
most recently filed return.
On December 10, 1992, the notice of deficiency was returned
to respondent marked “Not Deliverable”. Respondent inquired of a
credit bureau and obtained an address for a Curtis McIntosh at
2036 Parkamo Avenue, Hamilton, Ohio (the Ohio address). On
January 19, 1993, respondent verified the Ohio address with the
postmaster. On February 19, 1993, respondent sent petitioner a
letter requesting that he verify the Ohio address. Respondent
received no response to this request and did not resend the
notice of deficiency.
B. Notice and Demand for Payment
On April 26, 1993, respondent mailed to petitioner, at the
Kentucky address, a notice of balance due and demand for payment
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