- 11 - 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 OfficePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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