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circumstances of each case. Alta Sierra Vista, Inc. v.
Commissioner, supra at 374.
Petitioners' amended return for 1986 was the most recent
return filed by petitioners when the notice of deficiency was
issued on October 9, 1992. Respondent received that amended
return on May 14, 1991. On that return, petitioners listed their
address as the Route 208 address, consistent with their 1986 Form
1040. Petitioners did not file their 1991 return until 1995. The
record does not contain copies of petitioners' 1987, 1988, 1989,
or 1990 returns, and petitioners do not contend that those
returns listed an address other than the Route 208 address.
Printouts of the searches conducted on respondent's INOLE and
ENMOD computer databases, dated August 21, 1992, and October 1,
1992, indicate that petitioners listed their address as the Route
208 address on their 1988 and 1989 returns. On this record, we
find that respondent mailed the subject notice of deficiency to
the address shown on petitioners' most recent return.4
Petitioners argue that respondent knew that their address
had changed since their most recent return. Although petitioners
admitted at trial that they did not notify respondent
4 The record does not disclose whether petitioners' 1986
amended return had been properly processed by the Albany District
Office so that the address appearing on that return was available
to respondent's agent who prepared the subject notice prior to
its mailing. As noted, however, respondent's computer records
reflect that petitioners listed the Route 208 address on their
1988 and 1989 returns, and petitioners do not claim to have
listed a different address on their 1990 return.
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