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deficiency is mailed to a taxpayer's last known address, actual
receipt of the notice is immaterial. King v. Commissioner, 857
F.2d 676, 679 (9th Cir. 1988), affg. 88 T.C. 1042 (1987).
Although the phrase "last known address" is not defined in
the Code or the regulations thereunder, we have held that a
taxpayer's last known address is the address shown on the
taxpayer's most recently filed return, absent clear and concise
notice of a different address. Abeles v. Commissioner, 91 T.C.
1019, 1035 (1988). A taxpayer is obliged to provide respondent
with clear and concise notice of a change of address, but
respondent must exercise reasonable care and due diligence in
ascertaining the taxpayer's correct address. King v.
Commissioner, supra at 679. Once respondent has mailed the
notice of deficiency to the taxpayer's last known address,
respondent's reasonable care and due diligence obligation has
been satisfied. Id. at 681. The taxpayer bears the burden of
proving that the notice was not sent to the taxpayer's last known
address. Yusko v. Commissioner, 89 T.C. 806, 808 (1987). This
Court has previously held that a "return address placed on the
outside of an envelope, without more, does not constitute clear
and concise notification of a new, permanent address for purposes
of section 6212(b)(1)". James v. Commissioner, T.C. Memo. 1990-
128; see also King v. Commissioner, supra at 681.
In this case, petitioner wrote his new address only on the
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