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determining a deficiency, to send a notice of deficiency to the
taxpayer by certified or registered mail. A notice of deficiency
is sufficient if it is mailed to the taxpayer at the taxpayer's
"last known address". Sec. 6212(b)(1); Frieling v. Commissioner,
81 T.C. 42, 52 (1983). If a notice of 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 the
Commissioner with clear and concise notice of a change of
address, but the Commissioner must exercise reasonable care and
diligence in ascertaining the taxpayer's correct address.
Frieling v. Commissioner, supra at 49. In deciding whether the
Commissioner 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." Id. Once the Commissioner has mailed the
notice of deficiency to the taxpayer's last known address, the
Commissioner’s reasonable diligence obligation has been
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