Patrick Anthony Masino - Page 6

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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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