- 6 - determining his last known address, citing Keeton v. Commissioner, 74 T.C. 377 (1980). Petitioner argues that because the notice was not mailed to his last known address, the filing period should not begin until he actually received the notice of deficiency in late April 1996. On brief, petitioner maintains that agents for respondent were involved in the Federal criminal case and testified against petitioner at trial. Petitioner also contends that the Internal Revenue Service (IRS) supplied bank records and cash transaction reports to the Federal Bureau of Investigation and the U.S. attorney's office to prosecute the Federal money laundering case. There is no evidence in the record to either support or refute petitioner's allegations. Neither the Code nor the regulations define a taxpayer's "last known address". A taxpayer's last known address is the address to which, in light of all surrounding facts and circumstances, respondent reasonably believed the taxpayer wished the notice of deficiency to be sent. Monge v. Commissioner, 93 T.C. 22, 27-28 (1989). It is the taxpayer’s obligation to provide "clear and concise notification" to the IRS of any change of address. Alta Sierra Vista, Inc. v. Commissioner, 62 T.C. 367, 374-375 (1974), affd. without published opinion 538 F.2d 334 (9th Cir. 1976). Absent a clear and concise notification of a change in address, respondent is entitled to treat the address shown on the taxpayer’s most recently filed tax return as the last known address. Abeles v. Commissioner, supra at 1035. When notified of a change of address, respondent must exercisePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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