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1069, 1075-1076 (1928); see Miami Purchasing Service Corp. v.
Commissioner, 76 T.C. 818, 823 (1981); see also Minahan v.
Commissioner, 88 T.C. 492, 506 (1987).
Petitioner argues that the notice of deficiency was not
mailed to him until November 9, 1990, which is more than 3 years
after he filed his tax returns for 1982, 1983, and 1984 (see
supra table 2), and that assessment for those years is thus
barred by the statute of limitations. He contends that the
notice of deficiency mailed to the I.R.S. Classen address on
September 14, 1990, was invalid because it was not mailed to his
last known address and he did not receive it. He contends that
he notified respondent to use the P.O. drawer address and not the
Classen address.
Respondent contends, firstly, that the September 14, 1990,
notice of deficiency was mailed to petitioner's last known
address within 3 years after petitioner filed his tax returns for
1982 through 1986. Secondly, respondent contends that, even if
the Court concludes that the September 14, 1990, notice of
deficiency was not mailed to petitioner's last known address,
then this notice of deficiency is nevertheless valid because
petitioner received it and timely filed a petition with this
Court. Thirdly, respondent contends that, even if the September
14, 1990, notice of deficiency is not valid, then the November 9,
1990, notice of deficiency is timely, because petitioner omitted
more than 25 percent of his gross income for 1982 through 1984,
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