Maria E. Reed - Page 6

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          that a taxpayer's last known address is the address shown on the            
          taxpayer's most recently filed return, absent clear and concise             
          notice of a change of address.  Abeles v. Commissioner, 91 T.C.             
          1019, 1035 (1988); see King v. Commissioner, supra at 681.  The             
          burden of proving that a notice of deficiency was not sent to the           
          taxpayer at his or her last known address is on the taxpayer.               
          Yusko v. Commissioner, supra at 808.                                        
               Contrary to petitioner's view of the matter, we conclude               
          that the notice of deficiency was mailed to petitioner at her               
          last known address.  Respondent mailed the notice to petitioner             
          at the address appearing on petitioner's 1992 tax return; i.e.,             
          the Minden, Nevada address.  The record clearly shows that                  
          petitioner's 1992 tax return was the last return that petitioner            
          filed prior to the issuance of the notice of deficiency.                    
          Moreover, petitioner has failed to come forth with any evidence             
          tending to show that she provided respondent with clear and                 
          concise notice that she intended for respondent to correspond               
          with her at any address other than the Minden, Nevada, address.             
               Because the notice of deficiency was mailed to petitioner at           
          her last known address, we shall grant respondent's motion to               
          dismiss for lack of jurisdiction.5                                          
          In order to reflect the foregoing,                                          



           5  Although petitioner cannot pursue her case in this Court,               
          she is not without a legal remedy.  In short, petitioner may pay            
          the tax, file a claim for refund with the Internal Revenue                  
          Service, and if the claim is denied, sue for a refund in the                
          Federal District Court or the United States Court of Federal                
          Claims.  See McCormick v. Commissioner, 55 T.C. 138, 142 (1970).            



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