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examination notice was an initial contact letter and did not
offer petitioner an opportunity to meet with respondent’s Office
of Appeals (Appeals). One day before mailing the examination
notice to petitioner, respondent had checked his computer records
for petitioner’s address. Those records listed petitioner’s
address as 629 Mariola. Respondent did not mail an examination
notice to petitioner at 629 Mariola.
Petitioner timely filed (pursuant to extensions) a joint
2001 Federal income tax return (2001 return). Petitioner’s 2001
return was prepared by Campbell and reported that petitioner’s
address was 4302 Callahan. Respondent received petitioner’s 2001
return on October 21, 2002, and processed it on November 18,
2002.
On April 4, 2003, respondent checked his computer records
for petitioner’s address. Those records listed petitioner’s
address as 4302 Callahan. On the same day, respondent mailed a
Letter 915(DO) (30-day letter) for 2000 to petitioner at 4302
Callahan. The 30-day letter informed petitioner that he could
request a conference with the Appeals Office and was accompanied
by two copies of the examination notice. On September 19, 2003,
respondent mailed to petitioner at 4302 Callahan a Letter
1912(DO) that was accompanied by another copy of the examination
notice. The Letter 1912(DO) stated that respondent’s Small
Business and Self-Employed Division had reviewed petitioner’s
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Last modified: May 25, 2011