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Revenue Service to petitioner's employer on August 14, 1983. On
August 16, 1983, petitioner's employer, the Nuview Union School
District, completed and returned Form 3242 to the Internal
Revenue Service in San Diego, California. As completed, the Form
3242 identified petitioner's "current" address as the Apricot
address. Petitioner presented no evidence that she ever sent a
copy of the bankruptcy petition to respondent.
This Court repeatedly has held that notification by a third
party of a taxpayer's new address is not sufficient to provide
respondent with clear and concise notification of a taxpayer's
change of address. See Monge v. Commissioner, 93 T.C. 22 (1989)
(different addresses on Forms 4868 and 2688); Roy v.
Commissioner, T.C. Memo. 1992-559 (different address on a
bankruptcy cover sheet); Oak Center v. Commissioner, T.C. Memo.
1990-633 (Form 2848 where the Form did not expressly provide that
the taxpayers' address had changed); Grencewicz v. Commissioner,
T.C. Memo. 1990-597 (Forms 1099 and various other interest
statements filed by third parties); White v. Commissioner, T.C.
Memo. 1990-528 (a Form W-2 reflecting a different address);
Greenstein v. Commissioner, T.C. Memo. 1990-405 (Forms W-2 and
1099-DIV filed by third party payers). In United States v.
Zolla, 724 F.2d 808 (9th Cir. 1984), the Court of Appeals
indicated that third party notification would be adequate,
stating that "where the taxpayer himself did not communicate the
change of address to the IRS, the taxpayer would not be estopped
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