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responded to any of the examining agent’s attempts to communicate
with him.
Respondent’s agents can obtain a taxpayer’s address by
requesting an Inquiry National On-Line Entity (INOLE) report.
The database accessed through an INOLE report is maintained by
respondent and is updated with information from various sources,
including Federal income tax returns and Forms 8822, Change of
Address. Receipt of a Form 8822 by respondent is reflected on
an INOLE report; however, after the information contained on a
Form 8822 has been entered into the database, the form itself is
not retained.
According to INOLE reports generated on various dates from
May 26, 1993, through May 10, 1994, including January 5, 1994,
petitioner’s address was the San Leandro address. None of the
reports indicates the receipt of a Form 8822 from petitioner
during that period.
Discussion
Petitioner does not contend that the petition in this case
was timely filed. Instead, petitioner argues that the notice was
not mailed to him at his last known address.
In general, a taxpayer’s last known address is the address
shown on the most recently filed return, absent clear and concise
notice of a change in address. See King v. Commissioner, 857
F.2d 676, 679 (9th Cir. 1988), affg. 88 T.C. 1042 (1987); Abeles
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