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As indicated, the parties disagree whether the notices of
deficiency for 1988, 1989, and 1991 were mailed to petitioner at
her last known address as required by section 6212(b).
The phrase "last known address" is not defined in the Code
or in the regulations. We have held that a taxpayer's last known
address is the address shown on his or her most recently filed
return, absent clear and concise notice of a change of address.
Abeles v. Commissioner, 91 T.C. 1019, 1035 (1988). The burden of
proving that the notice of deficiency was not sent to the
taxpayer at his or her last known address is on the taxpayer.
Yusko v. Commissioner, supra at 808.
Respondent contends that the Summit Avenue address was
petitioner's last known address. In contrast, petitioner
contends that the P.O. Box 5072 address was her last known
address.
The record in this case convincingly demonstrates that the
Summit Avenue address was petitioner's last known address on each
of the three dates on which a notice of deficiency was mailed.
At the times that the notices of deficiency were sent to
petitioner, respondent's files included correspondence from
petitioner reflecting the Summit Avenue address as petitioner's
address. Also, at the times that the notices of deficiency for
1989 and 1991 were sent to petitioner, respondent possessed
petitioner's income tax return for 1988, petitioner's most
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