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of deficiency was not sent to the taxpayer's last known address
is on the taxpayer. Yusko v. Commissioner, supra at 808.
Respondent mailed the notice of deficiency to the Georgia
address listed on petitioners' 1990 amended tax return filed
March 21, 1994--the last tax return filed by either petitioner
prior to the mailing of the notice of deficiency. Consequently,
the notice of deficiency was mailed to petitioners' last known
address unless petitioners can demonstrate that they provided
respondent with clear and concise notice of a change of address.
Petitioners' assertion that the notice of deficiency is
invalid appears to be based on the related contentions that
respondent knew or should have known that the Georgia address
was an incorrect address, and that respondent received clear and
concise notice of petitioners' changes of address.
Petitioners point to petitioner's statement to Appeals
Officer Strain that petitioners were separated, as well as
petitioner's eviction from the Georgia address, as evidence that
respondent was aware that the Georgia address was not
petitioners' correct address.
We are not persuaded that respondent knew or should have
known that the Georgia address was an incorrect address. As we
see it, the import of petitioner's October 1993 statement to
Appeals Officer Strain that petitioners were no longer living
together was countermanded in March 1994 when petitioners filed
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