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was not reflected in the computer transcripts generated using New
Petroleum's EIN, which were used to confirm that the information
on the last three Forms 872 was correct.
Respondent's argument rests on the premise that any
knowledge of New Petroleum's merger obtained by personnel at the
Austin Service Center should not be attributed to the WPT agents,
because respondent did not have a computer system in place at the
time the last three Forms 872 were drafted, which would have
enabled the agents to access this information easily. We agree
with respondent. See also Southwestern Inv. Co. v. Commissioner,
19 B.T.A. 30 (1930) (citing Brant v. Virginia Coal & Iron Co., 93
U.S. 326, 337 (1876); cf. Abeles v. Commissioner, 91 T.C. 1019
(1988).
In Abeles v. Commissioner, supra at 1035, our decision
turned on the then-existing availability of computer-generated
information using the taxpayer's Social Security number. There,
we held that for purposes of determining whether a notice of
deficiency has been properly mailed to the taxpayer's last known
address, an agent issuing a deficiency notice generally is
charged with knowledge of a taxpayer's last known address which
appears on the taxpayer's most recently filed tax return. In
Abeles, we found as a fact that the then-existing computer
capabilities of the IRS were such that an agent responsible for
issuing a notice of deficiency had the ability to conduct, within
a few moments, a search of the IRS computer files for a more
recent address for the taxpayer. Id. at 1033-1035. In so
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