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In contrast, petitioner contends that his last known address
was either the Landrum Place address or "114 Nourcross Way".
Because no notice of deficiency was sent to him at either such
address, and further because he allegedly did not receive any
notice of deficiency, petitioner contends that the notices of
deficiency that were issued by respondent are invalid.6
The record in this case convincingly demonstrates that
either the Atteiram Drive address or the East 11th Street address
was petitioner's last known address. In view of the fact that
respondent mailed duplicate original notices of deficiency to
each such address, we need not decide whether the Atteiram Drive
address or the East 11th Street address was petitioner's last
known address.
In January 1993, petitioner filed his 1989 and 1991 income
tax returns. Both of those returns listed the East 11th Street
address as petitioner's home address, and those returns were the
ones that most recently preceded the mailing of the notices of
deficiency on June 11, 1993. Therefore, in the absence of clear
and concise notice of a change of address, the East 11th Street
6 As previously mentioned, actual receipt of a notice of
deficiency by a taxpayer is immaterial if the notice is mailed to
the taxpayer at the taxpayer's last known address. King v.
Commissioner, 857 F.2d 676, 679 (9th Cir. 1988), affg. 88 T.C.
1042 (1987); Yusko v. Commissioner, 89 T.C. 806, 810 (1987);
Frieling v. Commissioner, 81 T.C. 42, 52 (1983).
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