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February 15, 2004, and by respondent on March 29, 2004. On the
designated space for the taxpayer’s address on Form 872,
petitioner’s Georgetown, Texas, address is typed. However, on
one of the copies of this form, which was produced by respondent
from his records in digital CD format, there is a photocopy of a
post-it note in the middle with the handwritten notation “1752 W.
Muirwood DR, Phoenix, AZ 85045, new address” (Muirwood, Phoenix
address). It is not clear from the record when the handwritten
notation was added. Respondent concedes that the record does not
indicate how the Internal Revenue Service (IRS) was informed of
the new address.
On August 20, 2004, respondent received petitioner’s Form
2688, Application for Additional Extension of Time to File U.S.
Individual Income Tax Return, for taxable year 2003 that had
listed as his address “1111 South Creek Drive, #831, Round Rock,
TX 78664” (Round Rock, Texas, address). Petitioner also listed
the Round Rock, Texas, address as his address on his earlier
filed Form 4868, Application for Automatic Extension of Time to
File U.S. Individual Income Tax Return, and on his 2003 Form
1040, which was mailed on October 15, 2004, and received by
respondent on October 22, 2004.
Previously, respondent had issued a notice of deficiency on
June 10, 2004, for petitioner’s 2000 taxable year showing a
deficiency of $13,018. The record reflects that the notice of
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Last modified: November 10, 2007