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notice is nonetheless valid if the taxpayer receives actual
notice of the Commissioner's deficiency determination in a timely
fashion; i.e., without prejudicial delay. See Clodfelter v.
Commissioner, 527 F.2d 754 (9th Cir. 1975), affg. 57 T.C. 102
(1971); Mulvania v. Commissioner, 81 T.C. 65, 68-69 (1983), affd.
769 F.2d 1376 (9th Cir. 1985).
1. Last Known Address
As noted above, under section 6212 a notice of deficiency is
sufficient if it is mailed to the taxpayer's last known address
by certified or registered mail.
Neither section 6212 nor the regulations thereunder define a
taxpayer's "last known address". Generally, a taxpayer's last
known address is the address to which, in light of all
surrounding facts and circumstances, the Commissioner reasonably
believed the taxpayer wished the notice of deficiency to be sent.
Monge v. Commissioner, supra at 27-28. A taxpayer's last known
address is determined at the time the Commissioner mails the
notice of deficiency, and a notice mailed to the last known
address is valid even if the Commissioner later receives
information showing that the taxpayer resides at a different
address. See sec. 6212(b)(1); Monge v. Commissioner, supra at
33; Abeles v. Commissioner, supra at 1035.
In Abeles v. Commissioner, supra at 1035, we held that the
Commissioner is entitled to treat the address shown on a
taxpayer's most recent return as the taxpayer's last known
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