- 10 - 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).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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