Donna C. Clevenger - Page 11

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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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