James A. and Muriel M. Andrews - Page 13

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          Armstrong v. Commissioner, 15 F.3d 970, 974 (10th Cir. 1994)                 
          (quoted in Sicari v. Commissioner, supra at 930), affg. T.C.                 
          Memo. 1992-328.  In the circumstances, we believe the Box 227                
          address remained the last known address for purposes of section              
               It follows that respondent cannot be faulted for failing to             
          make the Braun Co. address available to the person responsible               
          for mailing the notice of deficiency or otherwise failing to                 
          enter the Braun Co. address in his databases.  This is not a case            
          where “the tax collector neglects to tell his right hand what his            
          left is doing”, Crum v. Commissioner, 635 F.2d 895, 900 (D.C.                
          Cir. 1980), but instead is a case where the tax collector, after             
          exercising reasonable diligence, “[has] no particular reason to              
          know”, Sicari v. Commissioner, supra at 930, which of two                    
          addresses is the one to which the taxpayer wishes the notice                 
          sent.  We also note that the only address instructions actually              
          signed by petitioners, namely, the instructions given on the Form            
          2848, were to use the Box 227 address.                                       
               Petitioners failed to give “clear and concise notification”             
          of a change of address from the Box 227 address used on their                
          most recently filed and properly processed return.  Follum v.                
          Commissioner, 128 F.3d at 119-120; Abeles v. Commissioner, 91                
          T.C. at 1035.  Under the facts of this case, to the extent that              
          respondent’s awareness of discrepancies in petitioners’ address              

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