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proving that a notice of deficiency was not sent to his last
known address. Yusko v. Commissioner, supra at 808.
Contrary to petitioner's position, we conclude that the
notices of deficiency were mailed to his last known address.
Respondent mailed the notices of deficiency to petitioner at the
Wilmington address--the address appearing on petitioner's 1994
tax return, which was the last return filed by petitioner prior
to the mailing of the notices of deficiency. Moreover,
petitioner concedes that, after filing his 1994 tax return but
prior to the mailing of the notices of deficiency, he did not
provide respondent with clear and concise notice that he intended
for respondent to correspond with him at any address other than
the Wilmington address.
Petitioner erroneously relies on Armstrong v. Commissioner,
15 F.3d 970 (10th Cir. 1994), affg. T.C. Memo. 1992-328, for the
proposition that his last known address is the address appearing
on his tax returns for the years in issue. Specifically,
Armstrong v. Commissioner, supra at 974, includes a statement,
consistent with the principle articulated above, that the address
on the taxpayer's most recent tax return is ordinarily treated as
the taxpayer's last known address. Although the court in
Armstrong held that the address appearing on the taxpayer's tax
returns for the years in issue constituted the taxpayer's last
known address, it did so only after finding that the revenue
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