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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
surrounding facts and circumstances, the Commissioner reasonably
believed the taxpayer wished the notice to be sent. Weinroth v.
Commissioner, supra. The relevant focus is thus on the
Commissioner's knowledge, rather than on what in fact may have
been the taxpayer's actual address in use. Brown v.
Commissioner, 78 T.C. 215, 219 (1982) (citing Alta Sierra Vista,
Inc. v. Commissioner, supra.)
In Abeles v. Commissioner, 91 T.C. 1019 (1988), we held that
a taxpayer's last known address is the address shown on his most
recent return, absent clear and concise notice of a change of
address. Monge v. Commissioner, supra at 28. However, once
respondent has become aware of a change in address, she must use
reasonable care and diligence in ascertaining and mailing the
notice of deficiency to the correct address. Whether respondent
has properly discharged this obligation is a question of fact.
Weinroth v. Commissioner, supra at 435-436; Alta Sierra Vista,
Inc. v. Commissioner, supra at 374.
A validly executed power of attorney may suffice to render
an attorney's address as the taxpayer's "last known address" if
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