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it directs that all original notices and written communications
be sent to the taxpayer at the attorney's address. See D'Andrea
v. Commissioner, 263 F.2d 904 (D.C. Cir. 1959); Reddock v.
Commissioner, 72 T.C. 21 (1979); Lifter v. Commissioner, 59 T.C.
818, 821 (1973).
The Forms 2848 executed by the parties in the above-cited
cases directed the taxpayers to choose between having originals
or copies of all notices and written communications sent to their
representatives. The new Form 2848, which was revised in March
of 1991 and which is involved in this case, provides simply that
"notices and other written communications will be sent" to the
taxpayer's designee. We have previously held that such language
is sufficient to render the address of the taxpayer's
representative as the "last known address" of the taxpayer. See
Honts v. Commissioner, T.C. Memo. 1995-532.
Even if a validly executed power of attorney directs that
all notices and communications relating to the taxpayers be
delivered to the attorney, the failure to send a notice of
deficiency to the attorney, as directed, is not necessarily
fatal. See Paul v. Commissioner, T.C. Memo. 1985-21. It is
clearly established that if mailing results in actual notice
without prejudicial delay, the notice of deficiency meets the
conditions of section 6212(a) no matter what address was used.
McKay v. Commissioner, 886 F.2d 1237 (9th Cir. 1989), affg. 89
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