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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
address.
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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