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their joint amended income tax return for 1990 listing the
Georgia address as their address. See, e.g., Joiner v.
Commissioner, T.C. Memo. 1992-300. Moreover, there is no
indication in the record presented that respondent was aware,
prior to mailing the notice of deficiency, that petitioner had
been evicted from the Georgia address. Consistent with the
foregoing, respondent did not receive clear and concise notice
that the Georgia address was not petitioners' current address,
and we so hold.
Petitioners' contention that respondent had clear and
concise notice of their changes of address is based on
petitioner's notification of her change of address to the
personnel department at the Atlanta Service Center and the
assertion that respondent had access to third-party information
returns (such as Forms W-2) listing petitioner John Stafford's
Brooklyn, New York address. We disagree with both of these
contentions.
Although we harbor serious doubt that change-of-address
information provided to the Commissioner in her role as an
employer should be considered clear and concise notice of a
change of address to the Commissioner in her role as
administrator of the Federal income tax, we note that petitioner
could not recall the exact date on which she advised the
personnel department at the Atlanta Service Center of her new
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