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return reflected the Colorado Springs Address, an address to
which respondent mailed a copy of the notice of deficiency. In
addition, respondent mailed a copy of the notice of deficiency to
two other addresses, the Nathrop Address--that of petitioner's
parents--and the Second Colorado Springs Address. Respondent
obtained the Second Colorado Springs Address as a result of a
request for information from one of petitioner's previous
employers. Prior to the mailing of the notice of deficiency,
respondent had not attempted to correspond with petitioner at the
Second Colorado Springs Address and therefore had no
"undelivered" mail from this address. Based on respondent's
inquiries, respondent may have concluded that the Second Colorado
Springs Address was petitioner's last known address.
Petitioner did not inform respondent of his address change
through written notice or otherwise. He did not file tax returns
for 1987 through 1994. As mentioned, if petitioner wanted
respondent to communicate with him at the Kansas Address, it
would have been a simple matter for him to inform respondent of
his change of address. Monge v. Commissioner, supra. Presumably
petitioner knew that he had failed to file tax returns for over 7
years and that respondent might attempt to contact him.
Petitioner contends that respondent could have ascertained
petitioner's current address by reviewing petitioner's transcript
of account, by observing that a Form 4868 had been filed for the
taxable year 1993, and by reviewing that form to determine
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