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preferences may have imposed on him any further obligation of
reasonable diligence, we believe he met that burden under the
standard applied by the Court of Appeals for the Second Circuit.
Cf. Sicari v. Commissioner, 136 F.2d 925 (2d Cir. 1998); Tadros
v. Commissioner, 763 F.2d 89 (2d Cir. 1985).
Our conclusion is reinforced in this case by the actions of
petitioners and their authorized representative, Mr.
Bezkorowajny. Mr. Bezkorowajny claims that he hand-delivered the
March 5 letter and power of attorney to the Taxpayer Service
Center in Brooklyn because he was endeavoring to comply with Rev.
Proc. 90-18, 1990-1 C.B. 491, which establishes procedures for
taxpayers to make a change of address, and because he wanted to
make certain that the agent auditing petitioners’ return would
receive the change of address “in time”--which we take to mean
before issuance of the notice or expiration of the 3-year period
of limitations, which was near. The problem with Mr.
Bezkorowajny’s explanation, as we see it, is that Rev. Proc. 90-
18, supra, provides a considerably more direct means of notifying
the examining agent of an address change when a taxpayer is under
audit. As an alternative to notice to the service center, Rev.
Proc. 90-18, supra, allows a taxpayer to effect a change of
address by notifying the IRS employee who has initiated contact
with him. If Mr. Bezkorowajny, a former IRS Appeals officer, had
as his goal the prompt notification of the examining agent, it is
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