Vincent J. and Susan L. Maranto - Page 6




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          February 1993 and which is involved in this case, provides simply           
          that “notices and other written communications will be sent” to             
          the taxpayer’s designee.  We have previously held that that                 
          language is sufficient to render the address of the taxpayer’s              
          representative the “last known address” of the taxpayer.  See               
          Honts v. Commissioner, T.C. Memo. 1995-532.  Under this                     
          principle, the notice mailed to Mr. Christensen at the Airway               
          Avenue address, and received by him, was sent to petitioners’               
          last known address.                                                         
               Petitioners contend that respondent should have mailed the             
          notice of deficiency to the Edinger Avenue address.  We disagree.           
          As indicated above, the address shown on petitioners’ most                  
          recently filed return serves as notice to respondent of                     
          petitioners’ last known address unless respondent was given clear           
          and concise notification of a change in that address.                       
          Accordingly, petitioners’ 1994 return, which was filed in October           
          of 1995, was the last filed return before the mailing of the                
          notice of deficiency for 1992.  Petitioners’ 1995 return showing            
          the Edinger Avenue address was filed after the mailing of the               
          notice of deficiency by certified mail to the Blake Road address.           
               Petitioners’ contention that they provided a new address to            
          respondent’s Appeals Office orally in a telephone conversation              
          has not been proven.  Petitioner husband testified to such a                
          conversation, but his testimony was rather vague.  On the                   





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