Donna C. Clevenger - Page 14

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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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