Manjit S. and Ravinder K. Aulakh - Page 6

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          the notice of deficiency to them at their last known address.  We           
          disagree.                                                                   
               Although the phrase "last known address" is not defined in             
          the Internal Revenue Code or in the regulations thereunder, we              
          have held that a taxpayer's last known address is the address               
          shown on the taxpayer's most recently filed return, absent clear            
          and concise notice of a change of address.  Abeles v.                       
          Commissioner, 91 T.C. 1019, 1035 (1988); see King v.                        
          Commissioner, supra at 681.  The burden of proving that a notice            
          of deficiency was not sent to a taxpayer at the taxpayer's last             
          known address is on the taxpayer.  Yusko v. Commissioner, supra             
          at 808.                                                                     
               Contrary to petitioners' view of the matter, we conclude               
          that the notice of deficiency was mailed to them at their last              
          known address.  In this regard, respondent mailed duplicate                 
          notices of deficiency to petitioners.  One of the notices was               
          mailed to the address appearing on their 1992 tax return (the               
          Hale St. address) and the other notice was mailed to the address            
          appearing on the Form 4868 (in respect of the taxable year 1993)            
          that petitioners filed with respondent on April 15, 1994 (the               
          Girard St. address).  The record clearly shows that petitioners'            
          1992 tax return was the last tax return that petitioners filed              
          before the notice of deficiency was issued.  Moreover,                      
          petitioners failed to produce any evidence showing that they                





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