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deficiency to be sent. Frieling v. Commissioner, 81 T.C. 42
(1983). “Absent ‘clear and concise notification’ from the
taxpayer directing respondent to use a different address,
respondent is entitled to treat the address shown on the return
* * * as the taxpayer's ‘last known address.’” Id. at 49; see
also Abeles v. Commissioner, 91 T.C. 1019 (1988) (address on most
recently filed return).
Petitioner has not alleged that he communicated an address
change to respondent in a clear and concise way. Petitioner
alleges only that he orally offered a preferred alternative
address.
Moreover, it is clear from petitioner’s own admission that
respondent did not take account of the change: “He [respondent’s
employee] apparently didn’t register that address change”, says
petitioner. Petitioner has not alleged facts to show that
respondent took account of the address change, such as by sending
correspondence to his new address before the notice of deficiency
was mailed to the old address. See Frieling v. Commissioner,
supra; Weinroth v. Commissioner, 74 T.C. 430 (1980).
Given that petitioner: (1) Used his residential address
rather than his Carnegie Mellon University address on his most
recently filed tax return, (2) had not moved from his residential
address at the time he allegedly advised respondent that the
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