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Although the phrase "last known address" is not defined in
the Internal Revenue Code or the regulations, we have held that
absent clear and concise notice of a change of address, a
taxpayer's last known address is the address shown on the
taxpayer’s return that was most recently filed at the time that
the notice was issued. Abeles v. Commissioner, 91 T.C. 1019,
1035 (1988); King v. Commissioner, supra at 681. In deciding
whether respondent mailed a notice to a taxpayer at the
taxpayer's last known address, the relevant inquiry "pertains to
respondent's knowledge rather than to what may in fact be the
taxpayer's most current address." Frieling v. Commissioner,
supra at 49. The burden of proving that the notice was not sent
to the taxpayer at the taxpayer's last known address is on the
taxpayer. See Yusko v. Commissioner, supra at 808.
Respondent mailed the notices of deficiency to the address
listed on petitioner's 1996 return--the last return filed by
petitioner prior to the mailing of the notices of deficiency in
October and December 1997. Consequently, the notices of
deficiency were mailed to petitioner at his last known address
unless petitioner can demonstrate: (1) He provided respondent
with clear and concise notice of a change of address; or (2)
prior to the mailing of the notices of deficiency, respondent
knew of a change in petitioner's address and did not exercise due
diligence in ascertaining petitioner's correct address. See
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