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against petitioner and her husband for the 1978 tax year. The
lien identifies petitioner's residence as the Bell Avenue
address. Respondent argues that because this lien was filed
based upon petitioner's last filed income tax return, an
inference can be made that respondent used petitioner's last
filed return to determine petitioner's address when filing this
lien. We conclude on the basis of the substantial available
evidence that the Bell Avenue address was the address listed on
petitioner's 1978 tax return and was petitioner's residence
address in February 1983 when she and her husband filed their
return for 1978.
Petitioner never sent notice to respondent specifically
informing respondent that the address on her most recent return
no longer should be used or that she wanted a different address
to be used for tax purposes. Based upon all the evidence in the
record, we find that respondent mailed the subject notice of
deficiency to the address which was shown as petitioner's
residence on her most recent return prior to the date of the
deficiency notice and which was in fact her residence at the time
of filing that return.
Petitioner argues that respondent knew that her address had
changed since her most recent return. She contends that
respondent knew of her address change by virtue of her bankruptcy
petition and a Form 3242 "Request for Information From Employer
(To Locate Individual)", which had been mailed by the Internal
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