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surrounding facts and circumstances, the Commissioner reasonably
believed the taxpayer wished the notice of deficiency to be sent.
Monge v. Commissioner, supra at 27-28. A taxpayer's last known
address is determined at the time the Commissioner mails the
notice of deficiency, and the notice is valid even if the
Commissioner later receives information showing that the taxpayer
resides at a different address. See sec. 6212(b)(1); Monge v.
Commissioner, supra at 33; Abeles v. Commissioner, supra at 1035.
In Abeles v. Commissioner, supra at 1035, we held that the
Commissioner is entitled to treat the address shown on a
taxpayer's most recent return as the taxpayer's last known
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, 763
F.2d at 92; White v. Commissioner, T.C. Memo. 1990-528. However,
if the Commissioner is notified of a change of address, she must
exercise reasonable care and diligence in ascertaining the
taxpayer's last known address. Abeles v. Commissioner, 91 T.C.
at 1031. Whether the Commissioner has exercised reasonable care
and diligence must be determined in light of the facts and
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