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and a timely filed petition. See Rule 13(a), (c); Monge v.
Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v.
Commissioner, 90 T.C. 142, 147 (1988). Section 6212(a)
authorizes the Secretary, upon determining that there is a
deficiency in income tax, to send a notice of deficiency “to the
taxpayer by certified or registered mail.” Section 6212(b)
provides that a notice of deficiency, in respect of an income
tax, “shall be sufficient” if it is “mailed to the taxpayer at
his last known address”. Generally, the Commissioner has no duty
to effect delivery of the notice after it is mailed to the
taxpayer’s last known address. See Monge v. Commissioner, supra
at 33.
Neither section 6212 nor the regulation promulgated
thereunder, section 301.6212-1, Proced. & Admin. Regs., defines
what constitutes a taxpayer’s “last known address”. We have
defined it as the taxpayer’s last permanent address or legal
residence known by the Commissioner, or the last known temporary
address of a definite duration to which the taxpayer has directed
the Commissioner to send all communications during that period.
See Weinroth v. Commissioner, 74 T.C. 430, 435 (1980); Alta
Sierra Vista, Inc. v. Commissioner, 62 T.C. 367, 374 (1974),
affd. without published opinion 538 F.2d 334 (9th Cir. 1976).
Stated otherwise, it is the address to which, in light of all the
surrounding facts and circumstances, the Commissioner reasonably
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