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agent had alertly discovered that the address appearing on the
taxpayer's most recent tax return was nonexistent. Id. In this
regard, petitioner's reliance on Armstrong is misplaced.
Petitioner also contends that respondent did not exercise
reasonable diligence in ascertaining his correct address.
Underlying this argument is petitioner's assumption that
respondent was aware, prior to issuing the notices of deficiency,
that the Wilmington address was incorrect. In particular,
petitioner contends that, because he did not receive the two
letters that respondent mailed to him at the Wilmington address
during August and September 1995, those letters must have been
returned to respondent undelivered. However, we are unable to
conclude, on the record presented, that the letters in question
were returned to respondent undelivered. In short, respondent
has no record in her files indicating that the letters were
returned undelivered, and petitioner presented no evidence to
show otherwise. Under the circumstances, we are not persuaded
that respondent failed to exercise reasonable diligence in
ascertaining petitioner's correct address.
In accordance with the preceding discussion, we hold that
respondent mailed the notices of deficiency to petitioner at his
last known address. As a consequence, we will grant respondent's
motion to dismiss for lack of jurisdiction on the ground that
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