- 14 - from arguing that a change of address noted by the IRS was incorrect." Id. at 811. The documents introduced by respondent in this case establish to our satisfaction that in February 1983, when petitioner and her husband filed their 1978 joint Federal income tax return, they were using the Bell Avenue address as their residence address and apparently listed that address on their return. Considering all the evidence available concerning petitioner's ownership of the Bell Avenue property and repeatedly claiming it as a residence address in contrast to her temporarily occupying quarters at her place of employment, the Apricot address, some time in 1983, we conclude that, on the date the deficiency notice was mailed, respondent reasonably believed that the Bell Avenue address was the address this taxpayer wished to have respondent use in sending mail to her. Thus, petitioner's last known address was the Bell Avenue address. Respondent mailed the subject notice of deficiency to the Bell Avenue address. That address would have been satisfactory to assure delivery to petitioner even if she had moved elsewhere in the Lakeview-Nuevo area. Respondent was not given clear and concise notification of a change of address. Therefore, we hold that the notice of deficiency with respect to petitioner's taxable years 1979 through 1981 was properly sent by respondent by certified mail to petitioner's last known address on April 13, 1984. Accordingly,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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