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demonstrate: (1) She provided respondent with clear and concise
notice of a change of address; or (2) prior to the mailing of the
deficiency notice for 1998, respondent knew of a change in
petitioner's address and did not exercise due diligence in
ascertaining petitioner's correct address. See Abeles v.
Commissioner, supra; Keeton v. Commissioner, supra at 382; Alta
Sierra Vista, Inc. v. Commissioner, 62 T.C. 367, 374 (1974),
affd. without published opinion 538 F.2d 334 (9th Cir. 1976).
There is nothing in the record to suggest that petitioner
gave respondent clear and concise notice of her change of address
from the Grasonville address to the Baltimore address.3 Nor is
there anything in the record to suggest that respondent knew
about such change of address. Indeed, given the short interval
between petitioner’s relocation in late November 1999 and the
issuance of the deficiency notice for 1998 on January 19, 2000,
there would have been limited opportunity for respondent to have
learned about petitioner’s change of address. Moreover, we take
3 The fact that petitioner may have provided notification
of her change of address to the U.S. Postal Service does not, in
and of itself, mean that petitioner provided notification to
respondent. See Adams v. Commissioner, T.C. Memo. 1994-365 (the
filing of a forwarding order with the Postal Service is not clear
and concise notification to the Commissioner of the taxpayer’s
change of address), affd. without published opinion sub nom.
Miller v. Commissioner, 61 F.3d 916 (10th Cir. 1995). In other
words, a taxpayer who does not notify the Commissioner of his or
her change of address but merely relies on the Postal Service to
forward mail bears the risk of any failure of the Postal Service
to properly forward such mail. Id.
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