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v. Commissioner, supra at 681. Once respondent has mailed the
notice of deficiency to the taxpayer's last known address, that
is all that is required, and respondent's reasonable care and
due diligence obligation has been satisfied. Id. The burden of
proving that a notice of deficiency was not sent to the
taxpayer's last known address is on the taxpayer. Yusko v.
Commissioner, supra at 808.
Respondent mailed the notice of deficiency to the Los
Angeles address listed on petitioners' 1995 joint tax return
filed April 15, 1996, the last tax return filed by petitioners
prior to the mailing of the notice of deficiency. Consequently,
the notice of deficiency was mailed to petitioners' last known
address unless petitioners can demonstrate that they provided
respondent with clear and concise notice of their change of
address.
Petitioners' assertion that the notice of deficiency is
invalid appears to be based on the contention that respondent
received clear and concise notice of petitioners' change of
address by virtue of petitioners' September 27, 1996 letter to
the Fresno Service Center. However, petitioners failed to
submit the letter to the Court for consideration. In any event,
insofar as the letter merely served as petitioners' request for
a copy of their 1993 tax return, it follows that the letter
would not constitute clear and concise notice of petitioners'
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