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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 not
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