- 11 - v. Commissioner, supra. Although the Commissioner must exercise reasonable diligence in ascertaining the taxpayer’s correct address, the burden necessarily falls upon the taxpayer to keep the Commissioner informed of her correct address. See Ramirez v. Commissioner, 87 T.C. 643 (1986); Alta Sierra Vista, Inc. v. Commissioner, supra. As we have stated: “When a taxpayer changes his address it is he who must notify the Commissioner of such change or else accept the consequences”. Alta Sierra Vista, Inc. v. Commissioner, supra at 374. In this case, petitioner timely notified respondent of her change of address from Crescent Avenue, the address on her 1997 tax return, to Oak Street, the address to which the notices of deficiency were mailed. The first question to be resolved is whether the October and November letters effected a change of address because of the Adele Street address appearing in the handwritten letterhead. This Court has held that an address written in the letterhead of a taxpayer’s correspondence, without more, will not constitute a clear and concise notification to the IRS of a change of address. See id.; Sanderson v. Commissioner, T.C. Memo. 1987-81. The taxpayer must advise the IRS that the new address is to be used in the future. Therefore, respondent properly mailed the notices of deficiency to petitioner’s last known address.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011