- 8 - Abeles v. Commissioner, supra; Keeton v. Commissioner, 74 T.C. 377, 382 (1980); Alta Sierra Vista, Inc. v. Commissioner, 62 T.C. 367, 374, affd. without published opinion 538 F.2d 334 (9th Cir. 1976). There is nothing in the record to demonstrate that petitioner gave respondent clear and concise notice of any change of address. Indeed, the record indicates that petitioner has at all relevant times regarded, and held out, the Ulloa Street address as his home address. On the other hand, respondent was informed in June 1997, before the notices were mailed, that petitioner was stationed overseas in Korea on a military assignment. We must decide, therefore, whether respondent exercised due diligence in mailing the notices to the Ulloa address. For the following reasons, we conclude that respondent exercised the requisite diligence. First, accepting petitioner’s allegation that he did not receive the notices of deficiency upon their mailing in October and December 1997, we observe that there is nothing in the record to indicate what petitioner’s actual address was at those times. Second, respondent searched respondent’s computer records in June 1997, and such search confirmed petitioner’s current address as the Ulloa Street address.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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