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jurisdiction.3 Monge v. Commissioner, 93 T.C. 22 (1989); Yusko v.
Commissioner, supra at 807.
The phrase "last known address" is not defined in the Internal
Revenue Code or the regulations. However, we have held that a
taxpayer's last known address is the address shown on his most
recently filed return, absent clear and concise notice of a change
of address. Abeles v. Commissioner, 91 T.C. 1019, 1035 (1988);
accord Aibejeris v. Commissioner, T.C. Memo. 1995-31. We have also
held that "last known address" is the address where the Commissioner
reasonably believed the taxpayer wished to be reached. Weinroth v.
Commissioner, 74 T.C. 430, 435 (1980); Keeton v. Commissioner, 74
T.C. 377, 381-382 (1980); Snow v. Commissioner, T.C. Memo. 1996-457.
The taxpayer bears the burden of proving that the notice of
deficiency was not sent to the taxpayer's last known address. Yusko
v. Commissioner, supra at 808. "Taxpayers are required to send a
clear and concise notification directing respondent to use a
different address to be assured of effecting a change in the 'last
known address.' Alta Sierra Vista, Inc. v. Commissioner, 62 T.C.
367, 374-375 (1974), and cases collected therein." Looper v.
Commissioner, 73 T.C. 690, 696 (1980). To supplant the address on
the most recent return, the taxpayer must clearly indicate that the
3 However, a notice of deficiency sent to the wrong
address is valid if it is received by the taxpayer without
prejudicial delay. Berger v. Commissioner, 404 F.2d 668 (3d Cir.
1968), affg. 48 T.C. 848 (1967); Goodman v. Commissioner, 71 T.C.
974 (1979).
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