Salvatore A. D'Onofrio - Page 3




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          his refusal to accept delivery of correspondence from                       
          respondent.3  On October 9, 1995, respondent assessed additional            
          tax, additions to tax, and interest against petitioner for 1990             
          and 1991.                                                                   
               On February 16, 1996, respondent mailed to petitioner a                
          notice of deficiency for 1992 and 1993.  Respondent sent the                
          notice to the following address:  Salvatore A. D’Onofrio, 676               
          Catalina Street, Laguna Beach, CA 92651-2545.  Petitioner again             
          refused to accept delivery of the notice, and on February 23,               
          1996, respondent received the returned notice of deficiency with            
          the words “Refused for Cause UCC 3-501 Without Dishonor”                    
          handwritten on the envelope.                                                
               Petitioner failed to petition this Court with respect to the           
          April 14, 1995, and February 16, 1996, notices of deficiency.               
               On June 1, 2005, respondent sent petitioner a Final Notice             
          of Intent to Levy and Notice of Your Right to a Hearing for 1990,           
          1991, 1992, and 1993.  In response, petitioner timely submitted a           
          Form 12153, Request for a Collection Due Process Hearing.                   
          Petitioner indicated that he disagreed with the proposed levy and           
          requested an audiotaped face-to-face hearing.  Petitioner did not           
          provide a phone number in his request.                                      


               3In the letters, petitioner argued that he did not have an             
          “address” but listed a mailing location at which he could be                
          reached:  “Salvatore A. D’Onofrio, Non Domestic Mail, c/o 676               
          Catalina, Laguna Beach, California”.                                        






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