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constituted “clear and concise” notice of a change of address not
only for petitioner, a point not really in dispute, but for
Douglas T. Busby as well. The Cherokee Drive address is
therefore petitioners’ last known address within the meaning of
section 6212, and the notice was properly mailed to them at that
address. See Abeles v. Commissioner, 91 T.C. 1019 (1988).
Because the petition in this case was not filed within the
period prescribed by section 6213(a), respondent’s motion will be
granted and the case will be dismissed for lack of jurisdiction
upon that ground.
To reflect the foregoing,
An appropriate order
dismissing this case for lack
of jurisdiction will be
entered.
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Last modified: May 25, 2011