- 6 - Instead, the notice was mailed to them at an address provided to respondent by petitioner in a telephone conversation that occurred sometime between June 24 and September 23, 1998. As a result of that telephone call, respondent’s records were changed not only with respect to petitioner’s address, but also with respect to Douglas T. Busby. Respondent’s internal procedures allow for other than written “clear and concise” notice of a change of address if such notice is received by, or provided to, respondent during the course of an income tax examination. See 4 Examination, Internal Revenue Manual, sec. 4243.1(2)(b) (Nov. 14, 1994); see also Westphal v. Commissioner, T.C. Memo. 1992-599. During the course of the examination of petitioners’ 1996 joint return, petitioner notified respondent of a change of address over the telephone, and petitioners’ address was changed as a result. As previously noted, neither of the petitioners notified respondent that they had established separate residences. According to his response to respondent’s motion, Douglas T. Busby, who apparently was aware of the then ongoing examination of his 1996 return, moved several times during the relevant period. Nothing in the record suggests that he notified respondent of any change of address. Under the circumstances, we are satisfied that petitioner’s telephone conversation providing notification of a new address to an IRS Service Center employeePage: Previous 1 2 3 4 5 6 7 Next
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