- 7 - Commissioner, supra. Although the Commissioner must exercise reasonable diligence in ascertaining the taxpayer's correct address, the burden necessarily falls upon the taxpayer to keep the Commissioner informed of his correct address. Ramirez v. Commissioner, 87 T.C. 643 (1986); Alta Sierra Vista, Inc. v. Commissioner, supra. As we have stated, "when a taxpayer changes his address it is he who must notify the Commissioner of such change or else accept the consequences". Alta Sierra Vista, Inc. v. Commissioner, supra at 374. In this case, it is undisputed that petitioner’s last filed return prior to the mailing of the 1993 notice of deficiency reflected the Studio City address. Accordingly, the Studio City address was petitioner’s last known address unless petitioner gave respondent clear and concise notification that his address had changed. Petitioner relies on the July 9, 1996, letter reflecting a new address in the upper right hand corner. We do not consider this clear and concise notification that petitioner’s address had changed. King v. Commissioner, supra at 681; Alta Sierra Vista, Inc. v. Commissioner, supra. First, the letter is addressed to the Internal Revenue Service (IRS) at its general mailing address and is not addressed to any particular department or individual. The record does not reflect what happens to letters so addressed. Respondent does not acknowledge having received that letter. Indeed, we do notPage: Previous 1 2 3 4 5 6 7 8 Next
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