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Generally, a taxpayer's "last known address" is the address
to which, in light of all surrounding facts and
circumstances, respondent reasonably believed the taxpayer
wished the notice of deficiency to be sent. [Citations
omitted.]
The record does not indicate that before September 14, 1990,
petitioner filed any tax returns after he filed his 1986 tax
return, on January 19, 1988. See supra table 2. Thus, when the
notice of deficiency was sent, the most recently filed tax return
was the 1986 tax return. The address shown on the 1986 tax
return is the tax return Classen address. (The bankruptcy
discharge order, which shows the P.O. drawer address, preceded
petitioner's filing of his tax returns for 1982 through 1986.)
The address to which the September 14, 1990, notice of deficiency
was sent (the I.R.S. Classen address) is the same as the tax
return Classen address, except for the ZIP code. The tax return
Classen address includes the ZIP code 73069; the I.R.S. Classen
address includes the ZIP code 73071-4616. Each U.S. Postal
Service's annual National Five-Digit ZIP Code and Post Office
Directory for 1987 through 1993 shows that (1) Classen Blvd. for
Norman, Oklahoma, is in ZIP code 73071, (2) Classen Cir. for
Norman, Oklahoma, is in ZIP code 73072, and (3) ZIP code 73069 is
in Norman, Oklahoma, but does not include any street named
"Classen". We conclude (a) that petitioner erred on his tax
returns, as well as other documents referred to in our findings,
when he used the ZIP code 73069, and (b) that respondent's use of
the I.R.S. Classen address on the September 14, 1990, notice of
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