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filing of a document, such as a Form 4868, indicating a different
address than the taxpayer's address on file, does not give the
Commissioner clear and concise notification of a change of
address. See, e.g., Monge v. Commissioner, supra (Forms 4868 and
2688, extension forms); Mollet v. Commissioner, 82 T.C. 618
(1984), affd. without published opinion 757 F.2d 286 (11th Cir.
1985) (a Tax Court petition); McCormick v. Commissioner, 55 T.C.
138 (1970) (an informal letter advising the IRS of an address
change); Cantu v. Commissioner, T.C. Memo. 1990-354 (Form 4868);
Pritchett v. Commissioner, T.C. Memo. 1986-559 (a letter with new
address at the bottom without any comment); Marlin v.
Commissioner, T.C. Memo. 1985-600 (Form 2848, power of attorney).
In this regard, we observed in Monge v. Commissioner, 93 T.C.at
32:
Perhaps the most significant objection to * * * [the
taxpayers'] position is that it would require * * *
[the Commissioner] to record the address shown on every
extension request filed with him. The adoption of
their position would clearly upset the balance between
the administrative burdens imposed on * * * [the
Commissioner] and the interest of taxpayers in
obtaining actual notice of * * * [the Commissioner's]
determination. If * * * [the taxpayer] had wanted * *
* [the Commissioner] to use the address shown on * * *
Form 4868 * * * as his last known address, it would
have been a simple matter for him to have so indicated
on the form itself. * * *[The taxpayer] chose not to
do so and thereby failed to clearly and concisely
notify * * * [the Commissioner] of the desired change.
Accordingly, we hold that the Forms 4868 * * * filed by
* * * [the taxpayer] * * * did not provide clear and
concise notification to * * * [the Commissioner] of * *
* [the taxpayer's] change of address. [Citations
omitted.]
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