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B. Respondent's Due Diligence
We have held that the Commissioner must exercise reasonable
diligence and care in ascertaining the taxpayer's current address
once the Commissioner becomes aware of a change in the taxpayer's
address. Abeles v. Commissioner, supra; Keeton v. Commissioner,
74 T.C. 377, 382 (1980); Alta Sierra Vista, Inc. v. Commissioner,
supra at 374. Thus, if previous correspondence mailed by the
Commissioner to a taxpayer is returned as undeliverable before
the notice of deficiency is mailed, the Commissioner could
reasonably be expected to conduct a further inquiry. See Abeles
v. Commissioner, supra.
Clearly, in the present case, respondent was aware of a
change in petitioner's address due to the fact that prior
correspondence to petitioner had been returned as undeliverable.
At this point, we must consider the nature of respondent's duty
of due diligence and whether respondent discharged that duty.
The Court will consider all of the facts and circumstances
in deciding whether respondent exercised reasonable care in
ascertaining the taxpayer's current address. Weinroth v.
Commissioner, 74 T.C. 430, 435 (1980). In this context, our
inquiry requires an analysis of the efforts made by respondent to
determine the address for mailing the notice of deficiency. Id.
Courts have typically held that the Commissioner has failed
to discharge the duty of reasonable diligence if a search in the
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