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v. Commissioner, 91 T.C. 1019, 1035 (1988). Relevant for our
purposes, a Form 8822 is one method that a taxpayer can use to
provide such notice. See sec. 5.04(3) of Rev. Proc. 90-18, 1990-
1 C.B. 491, 494.
At the hearing, petitioner testified that on July 7, 1993,
or shortly thereafter, he sent by regular mail a Form 8822 (the
form) to respondent changing his address from the San Leandro
address to 29261 Harpoon Way, Hayward, CA 94544 (the Hayward
address). Petitioner claims that the form was sent prior to
respondent’s issuance of the notice, and, therefore, the Hayward
address was his last known address at the time the notice was
issued.
We note that petitioner’s claim regarding the mailing of the
form was not made known until later in the proceedings. The
petition does not contain any express reference to the form, nor
does it indicate what address petitioner claims to have been his
last known address on the date the notice was mailed.4 Instead,
petitioner’s first reference to the form and the Hayward address
is set forth in a declaration attached to his objection to the
4 In the petition, petitioner alleges that respondent was
put on notice of his change of address “through correspondence
and/or return filing before the mailing of the notice of
deficiency”. We doubt that petitioner intended the term
“correspondence” to include the form. Furthermore, the San
Leandro address is the address listed for petitioner on the most
recently filed return prior to the issuance of the notice.
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