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Further, the notice of deficiency was returned to respondent
marked "Unclaimed" (as opposed to "Addressee Unknown",
"Insufficient Address" or "Unable to Forward"), indicating that
certified mail notices were left at the Lightning View address,
yet the notice of deficiency was not claimed. See, e.g., Erhard
v. Commissioner, T.C. Memo. 1994-344, affd. 87 F.3d 273 (9th Cir.
1996).
Petitioner contends that he provided oral notice to
respondent's revenue officers in the fall of 1983 that he had
changed his address to the Rogers Avenue address. However, the
revenue officers who were in contact with the Thomases during
this period could not recall being informed of, or ever visiting,
the Rogers Avenue address. The record does show that
respondent's Collection Branch in Philadelphia was aware that
petitioner might be contacted at the Rogers Avenue address--the
Collection Branch used that address in mailing the Form 4901 to
petitioner on December 30, 1983. The revenue officers from the
Collection Branch in Philadelphia were not involved with the
examination of petitioner's individual income tax liability for
1978. They were concerned with efforts to collect Delafield's
unpaid Federal employment taxes for 1980 and 1981 and/or the
imposition of the 100-percent responsible person penalty against
the Thomases with respect to those taxes, whereas the deficiency
notice for Federal income tax for 1978 was issued by the District
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