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Commissioner's computer databases would reveal a taxpayer's
correct address. E.g., Abeles v. Commissioner, supra; Taylor v.
Commissioner, T.C. Memo. 1988-152. On the other hand, courts
have refused to impute knowledge to the Commissioner of all
address information listed on all the various forms (such as
Forms 4868) and correspondence received by the Commissioner.
See, e.g., Guillen v. Barnes, supra at 977; Monge v.
Commissioner, 93 T.C. 22 (1989); Mollet v. Commissioner, 82 T.C.
618 (1984), affd. without published opinion 757 F.2d 286 (11th
Cir. 1985); McCormick v. Commissioner, 55 T.C. 138 (1970);
Pritchett v. Commissioner, T.C. Memo. 1986-559; Marlin v.
Commissioner, T.C. Memo. 1985-600. The objective is to strike a
balance between the administrative burden placed on the
Commissioner and the taxpayer's interest in timely receiving a
notice of deficiency.
In view of the foregoing and in the context of the specific
facts of the present case, we must decide whether respondent
satisfactorily discharged the duty of due diligence in mailing
the notice of deficiency to petitioner. For the following
reasons, we hold that he did.
Because respondent does not retain any address information
that may be listed on a Form 4868, none of respondent's computer
databases reflected petitioner's Kansas Address when the notice
of deficiency was mailed. Petitioner's most recently filed
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