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mailbox number 2913, when the correct number was 29136. In the
notice of no objection to petitioner’s motion to dismiss,
respondent conceded that the notices of deficiency were not
mailed to petitioner’s last known address.
Petitioner contends that mailing the notices of deficiency
to the wrong addresses was unreasonable because respondent should
have been able to glean her correct addresses from various Forms
W-2 filed by her former employers.7
In determining a taxpayer’s “last known address” we have
repeatedly held that the burden is on the taxpayer to provide the
Commissioner with clear and concise notification of her new
address. Pyo v. Commissioner, 83 T.C. 626, 636 (1984); Mollet v.
Commissioner, 82 T.C. 618, 623 (1984). While the Commissioner
must exercise reasonable diligence in ascertaining the taxpayer’s
correct address, administrative realities demand that the burden
necessarily falls upon the taxpayer to keep respondent informed
of his or her correct address or “accept the consequences”. Alta
Sierra Vista, Inc. v. Commissioner, 62 T.C. 367, 374 (1974).
Two relevant factors that influence our decision are
7Petitioner’s motion papers reveal that she frequently
changed addresses and employers. Two Forms W-2 filed by former
employers for 1993 have different addresses: 1832 Merchant
# 103, Sparks, NV, and 3702 S. Virginia G12-243, Reno, NV. A
Form W-2 filed in 1994 by another employer shows petitioner’s
address as 2850 Needles # 29136, Laughlin, NV. Finally, a 1995
Form W-2, also filed by a different employer, shows petitioner’s
address as 6200 Meadowood, Reno, NV.
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