Audrey Carlisle - Page 11




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          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.                                                              








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