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petitioner’s last known address to dispose of the motions before
us, however, because that fact is immaterial to respondent’s
principal argument that petitioner received actual notice of the
October 6 notice and timely filed the petition. Respondent
argues that we can assume that the October 6 notice was not
addressed to petitioner’s last known address and decide whether,
notwithstanding that assumption, the October 6 notice was
sufficient to suspend the running of the period of limitations.
Petitioner argues that the October 6 notice was insufficient
to suspend the running of the period of limitations because
(assuming that it was not sent to petitioner’s last known
address) respondent abandoned or withdrew the October 6 notice
when all three copies were returned undelivered by the Postal
Service and respondent communicated a copy to petitioner’s agent,
Levin, by facsimile transmission on November 10, 1994. That
facsimile transmission (the November 10 communication), argues
petitioner, constituted a new notice of deficiency, which was
effective (once the petition was filed) to give this Court
jurisdiction but which was ineffective, because untimely, to
suspend the running of the period of limitations.
In support of its argument, petitioner cites Reddock v.
Commissioner, 72 T.C. 21 (1979). In the Reddock case, respondent
mailed a notice of deficiency to the taxpayers 3 days before the
expiration of the period of limitations (the initial notice) but
did not mail the initial notice to the taxpayers' last known
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