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address, absent clear and concise notification of an address
change. When a taxpayer changes his address, the taxpayer must
notify the Commissioner of the change or else accept the
consequences. Alta Sierra Vista, Inc. v. Commissioner, 62 T.C.
367, 374 (1974), affd. without published opinion 538 F.2d 334
(9th Cir. 1976). To supplant the address on the most recent
return, the taxpayer must clearly indicate that the former
address is no longer to be used. Tadros v. Commissioner, supra
at 92; White v. Commissioner, T.C. Memo. 1990-528.
In the present case the record shows that the notice of
deficiency was mailed to the address on petitioner's most recent
return, and petitioner has failed to show that he notified
respondent of a change of address.
The deficiency notice was mailed to petitioner at 2407
Lascar Place, San Jose, CA 95124 (2407 Lascar), the address
listed as petitioner's home address on the 1992 tax return that
he filed on August 17, 1993, and also on the amended return for
1992 that he filed on December 15, 1993. At the time of the
hearing on respondent's motion to dismiss, petitioner had not yet
filed a return for 1993. Petitioner's return for 1994 was not
yet due when the deficiency notice was mailed, and petitioner
concedes that as of the end of 1995 he had not filed a return for
any year after 1992.
Petitioner argues that he moved from 2407 Lascar to 13
Skylark Drive, Apt. 5, Larkspur, CA 94939 (13 Skylark Drive) in
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