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period for filing a timely petition with respect to either of the
notices of deficiency, it follows that we lack jurisdiction over
the petition. Secs. 6213(a) and 7502; Rule 13(a), (c); see
Normac, Inc. v. Commissioner, supra.
The question presented is whether dismissal of this case
should be premised on petitioner's failure to file a timely
petition under section 6213(a) or on respondent's failure to
issue valid notices of deficiency under section 6212. Petitioner
contends that respondent failed to mail the notices of deficiency
to his last known address. We disagree.
Although the phrase "last known address" is not defined in
the Internal Revenue Code or in the regulations, we have held
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.
There does not appear to be any dispute that the notice of
deficiency for 1990 was mailed to petitioner's correct address
but for his separation from his wife at the time the notice was
issued. In the absence of any evidence that petitioner notified
respondent that he was living at an address other than the
Fayetteville address at that time, we conclude that respondent
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