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v. Commissioner, T.C. Memo. 1992-559 (different address on a
bankruptcy cover sheet); White v. Commissioner, supra (a Form W-2
reflecting a different address); see also Stein v. Commissioner,
T.C. Memo. 1990-378. In addition, based on our review of the
record, and in particular Manico's testimony, we hold that
respondent exercised reasonable care and diligence in
ascertaining petitioners' last known address. Petitioners'
reliance upon cases in which respondent received a subsequently
filed tax return and/or other clear and concise notice of an
address change is misplaced.6
The testimony of employees at the Gardiner Post Office
supports the view that in practice mail addressed to petitioners
at the Route 208 address during 1992 was properly addressed to
them, regardless of whether the address also referred to Box 1370
or house number 871. Both the Postmaster for Gardiner during
1992, Walker, and the letter carrier responsible for delivering
mail to petitioners in 1992, Williams, testified at trial.
Walker identified her handwriting at the top of the envelope in
which the notice was mailed. This identification satisfies us
that the Gardiner Post Office handled the notice. Walker also
6 In their posttrial brief, petitioners relied upon the
following cases: King v. Commissioner, 857 F.2d 676 (9th Cir.
1988), affg. 88 T.C. 1042 (1987); Cool Fuel, Inc. v. Connett, 685
F.2d 309 (9th Cir. 1982); McPartlin v. Commissioner, 653 F.2d
1185 (7th Cir. 1981); Crum v. Commissioner, 635 F.2d 895 (D.C.
Cir. 1980); Pyo v. Commissioner, 83 T.C. 626 (1984); Weinroth v.
Commissioner, 74 T.C. 430 (1980); Gibson v. United States, 761 F.
Supp. 685 (C.D. Cal. 1991).
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