- 15 - deficiency to be sent. Frieling v. Commissioner, 81 T.C. 42 (1983). “Absent ‘clear and concise notification’ from the taxpayer directing respondent to use a different address, respondent is entitled to treat the address shown on the return * * * as the taxpayer's ‘last known address.’” Id. at 49; see also Abeles v. Commissioner, 91 T.C. 1019 (1988) (address on most recently filed return). Petitioner has not alleged that he communicated an address change to respondent in a clear and concise way. Petitioner alleges only that he orally offered a preferred alternative address. Moreover, it is clear from petitioner’s own admission that respondent did not take account of the change: “He [respondent’s employee] apparently didn’t register that address change”, says petitioner. Petitioner has not alleged facts to show that respondent took account of the address change, such as by sending correspondence to his new address before the notice of deficiency was mailed to the old address. See Frieling v. Commissioner, supra; Weinroth v. Commissioner, 74 T.C. 430 (1980). Given that petitioner: (1) Used his residential address rather than his Carnegie Mellon University address on his most recently filed tax return, (2) had not moved from his residential address at the time he allegedly advised respondent that thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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