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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 employee
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