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satisfied. King v. Commissioner, supra at 679. 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).
On January 6, 1994, respondent's records showed petitioner's
last known address as the Albuquerque address based upon
petitioner's latest and most recently filed Federal tax return
which was for the 1986 taxable year. Respondent's records also
showed the Attleboro address based upon third party payer
information reported by American Auto Transporters, Inc.
regarding Forms 1099-Misc issued to petitioner for the years 1992
and 1993.
On July 26, 1994, respondent sent Address Information
Request Forms 4759 to the U.S. Post Offices of Albuquerque and
Attleboro to verify whether mail was deliverable to the
respective addresses. The Albuquerque post office returned the
form stating "Mail Is Delivered To Address Given". The Attleboro
post office returned the form stating "Not Known At Address
Given".
On February 29, 1996, prior to mailing the notice of
deficiency, respondent verified that petitioner's last known
address (Albuquerque address) had not changed. The Internal
Revenue Service computer records which were printed on February
29, 1996, show that the Albuquerque and Attleboro addresses were
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