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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,
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