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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
6212(b)(1).
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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