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OPINION
Section 6501(a) provides that the amount of any deficiency
in income tax shall be assessed within 3 years after the return
was filed. Section 6503(a) provides, however, that the running
of the 3-year period of limitations is suspended by "the mailing
of a notice under section 6212(a)." Section 6212(a) authorizes
the Secretary or his delegate, upon determining that there is a
deficiency in income tax, to send a notice of deficiency "to the
taxpayer by certified mail or registered mail." Section
6212(b)(1) provides that a notice of deficiency, in respect of an
income tax, "shall be sufficient" if it is "mailed to the
taxpayer at his last known address". Generally, the Commissioner
has no duty to effectuate delivery of the notice after it is
mailed. Monge v. Commissioner, 93 T.C. 22, 33 (1989).
Neither section 6212 nor the regulation promulgated
thereunder, section 301.6212-1, Proced. & Admin. Regs., defines
what constitutes a taxpayer's "last known address". We have
defined it as the taxpayer's last permanent address or legal
residence known by the Commissioner, or the last known temporary
address of a definite duration to which the taxpayer has directed
the Commissioner to send all communications during such period.
Weinroth v. Commissioner, 74 T.C. 430, 435 (1980); Alta Sierra
Vista, Inc. v. Commissioner, 62 T.C. 367, 374 (1974), affd.
without published opinion 538 F.2d 334 (9th Cir. 1976). Stated
otherwise, it is the address to which, in light of all the
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