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lacks jurisdiction in this case. Nonetheless, we must decide
whether dismissal of this case should be premised on petitioner's
failure to file a timely petition under section 6213(a) or on
respondent's failure to issue a valid notice of deficiency under
section 6212. See Pietanza v. Commissioner, 92 T.C. 729, 735-736
(1989), affd. without published opinion 935 F.2d 1282 (3d Cir.
1991). In this regard, we must determine whether respondent
mailed the notice of deficiency in question to petitioner's last
known address.
Although the phrase "last known address" is not defined in
the Internal Revenue Code or in the regulations, we have held
that a taxpayer's last known address normally is the address
shown on the taxpayer's most recently filed return, absent clear
and concise notice of a change of address. Abeles v.
Commissioner, 91 T.C. 1019, 1035 (1988); see King v.
Commissioner, supra at 681. Oral notification of a change of
address, clearly proved, may be sufficient to constitute a change
of address. See Mollet v. Commissioner, 82 T.C. 618, 625-626
(1984), affd. without published opinion 757 F.2d 286 (11th Cir.
1985); Westphal v. Commissioner, T.C. Memo. 1992-599.
The record in this case shows that respondent mailed the
notice of deficiency to the address appearing on petitioner's
1978, 1979, and 1980 tax returns--petitioner's most recently
filed tax returns before the mailing of the notice of deficiency.
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