- 21 - 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 soPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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