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whether the notice was mailed to his last known address. For the
following reasons, we find that it was.
Having determined a deficiency in petitioners’ 1996 Federal
income tax, respondent was authorized to send by certified or
registered mail a notice of deficiency to petitioners at their
“last known address”. Sec. 6212(a) and (b). Petitioners filed a
joint Federal income tax return for 1996. Section 6212(b)(2)
states that: “In the case of a joint income tax return filed by
husband and wife, such notice of deficiency may be a single joint
notice, except that if the Secretary has been notified by either
spouse that separate residences have been established, then, in
lieu of the single joint notice, a duplicate original of the
joint notice shall be sent by certified mail or registered mail
to each spouse at his last known address.” (Emphasis added.)
Petitioners do not contend, and nothing in the record
demonstrates, that either of them notified respondent that they
had established separate residences.
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
v. Commissioner, 91 T.C. 1019, 1035 (1988).
In this case, the notice was not mailed to petitioners at
the address listed on their most recently filed joint return.
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