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reasonable care and diligence in ascertaining and mailing the
notice of deficiency to the correct address. Looper v.
Commissioner, 73 T.C. 690, 696 (1980); Alta Sierra Vista, Inc. v.
Commissioner, supra at 374. Whether respondent has exercised
reasonable care and diligence must be determined in light of the
facts and circumstances of each case. Alta Sierra Vista, Inc. v.
Commissioner, supra.
In Keeton v. Commissioner, supra, we found that information
concerning the taxpayer's address in the possession of the U.S.
Department of Justice (DOJ) was imputed to respondent. The DOJ
had obtained the taxpayer's address in criminal tax proceedings.
We reasoned that the IRS was inextricably connected with the U.S.
Government's investigation, prosecution, and conviction of the
taxpayer and, therefore, was on notice of the taxpayer's
incarceration. The Court further reasoned that the DOJ and the
IRS are both administrative agencies of the executive branch of
the Federal Government and work in conjunction to enforce Federal
income tax laws. Respondent argues that this case is
distinguishable from Keeton v. Commissioner, supra, because the
office of pretrial services is part of the judicial branch. In
this regard, respondent argues that information possessed by a
judicial office should not be imputed to respondent. Respondent
contends that information obtained by the office of pretrial
services is not available to respondent without approval from the
U.S. District Court, citing 18 U.S.C. sec. 3153 (1994).
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