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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.
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