Theolia Millsap - Page 11

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            address was petitioner's last known address under the rationale                             
            of Abeles v. Commissioner, supra at 1035.                                                   
                  Although there is no indication that petitioner himself ever                          
            gave respondent clear and concise notice of a change of address,                            
            respondent was advised by a third party, early in 1993, that                                
            petitioner was residing at the Atteiram Drive address.                                      
            Respondent's agents confirmed this fact by actual observation of                            
            petitioner at the Atteiram Drive address and by executing a writ                            
            of entry at that address on April 19, 1993.  Moreover, the                                  
            jeopardy notices that were mailed to the Atteiram Drive address                             
            were delivered to, and receipted by, "Bertha Millsap" on April                              
            24, 1993.  Accordingly, it was reasonable for respondent to mail                            
            duplicate original notices of deficiency to the Atteiram Drive                              
                  The foregoing analysis, coupled with petitioner's admission                           
            that he was actually living at the Atteiram Drive address on June                           
            11, 1993, leads us to reject petitioner's contention that his                               
            last known address was either the Landrum Place address or "114                             
            Nourcross Way".  Insofar as the Landrum Place address is                                    
            concerned, we observe that that address first came to light in                              
            October 1993, 4 months after the mailing of the notices of                                  
            deficiency, when respondent's collection officer seized an                                  
            automobile operated by Mrs. Millsap.  And insofar as "114                                   
            Nourcross Way" is concerned, we observe that no document in the                             

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