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Commissioner, 62 T.C. 367, 374 (1974), affd. without published
opinion 538 F.2d 334 (9th Cir. 1976). To supplant the address on
the most recent return, the taxpayer must clearly indicate that
the former address is no longer to be used. Tadros v.
Commissioner, 763 F.2d 89, 92 (2nd Cir. 1985); White v.
Commissioner, T.C. Memo. 1990-528.
Petitioner's joint Federal income tax return for 1978, filed
February 2, 1983, was the most recent return filed by petitioner
when the notice of deficiency was issued on April 13, 1984.
Petitioner bears the burden of proving that the notice of
deficiency was not mailed to her last known address. Rule
142(a); Yusko v. Commissioner, 89 T.C. 806, 808 (1987).
Moreover, regardless of the burden of proof, the record before us
is replete with documents indicating that in February 1983 when
petitioner's most recent return was filed, petitioner and her
husband considered the Bell Avenue address their residence
address. Among the documents introduced as evidence by
respondent were petitioner's bankruptcy records, official
employment records, including her wage reports and personnel
records, records from the California Department of Motor
Vehicles, and an Abstract of Judgment and Notice of Judgment Lien
filed by First Interstate Bank of California against petitioner
and her husband.
On October 22, 1984, respondent filed a "Notice of Federal
Tax Lien" with the Riverside, California, Recorder's Office
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