- 6 - was mailed to an address that is identical to the address petitioners listed on the Federal income tax return they filed most recently before the mailing of the notices of deficiency. The other notice of deficiency was mailed to petitioners at a similar address except the word "Creek" was omitted. Petitioners never provided clear and concise notice to respondent that they wanted to be contacted at a different address. During cross- examination, petitioner testified as follows: Q. Okay. Have you ever sent the Internal Revenue Service a notice or requested in any way that they not send notices of deficiency related to your personal tax situation? Have you ever requested they send those notices to any address other than HC 71 Lone Pine Road, Burns, Oregon, 97720? A. I've never requested they send them to any address so the answer is no. We are further satisfied that at least one of the notices of deficiency was addressed to petitioners at their last known address (according to the testimony of the U.S. Postal Service employee, both addresses were proper). See King v. Commissioner, 857 F.2d 676 (9th Cir. 1988), affg. 88 T.C. 1042 (1987); Abeles v. Commissioner, 91 T.C. 1019, 1035 (1988). Petitioners argue that respondent was aware of numerous other addresses used by petitioner as a tax matters partner in various partnerships. According to petitioners, any of these other addresses should be considered their last known addressPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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