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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 exercise
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