- 4 - nor the regulation promulgated thereunder defines what constitutes a taxpayer's "last known address". Generally, a taxpayer's last known address is the address shown on her most recently filed and properly processed return, absent clear and concise notice of a different address. Abeles v. Commissioner, 91 T.C. 1019, 1035 (1988); Alta Sierra Vista, Inc. v. Commissioner, 62 T.C. 367, 374 (1974), affd. without published opinion 538 F.2d 334 (9th Cir. 1976). The focus is on what the Commissioner knew or should have known at the time the notice of deficiency was mailed. Petitioner has the burden of proving that the notices of deficiency were not sent to her last known address. Yusko v. Commissioner, 89 T.C. 806, 808 (1987). Petitioner's most recently filed Federal income tax return prior to the mailing of the notices of deficiency was for taxable year 1981. Petitioner asserts that the address shown on that return was 9335 S.W. Downing, Portland, Oregon, and she contends that this was her last known address at the time the notices of deficiency were mailed. Petitioner has failed to convince us of this fact through her testimony or otherwise. Petitioner did not produce a copy of her Federal income tax return for the taxable year 1981. Respondent destroyed petitioner's original returns filed for 1979 and 1981 in accordance with respondent's procedures. Petitioner does notPage: Previous 1 2 3 4 5 6 7 8 Next
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