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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 not
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