Thomas R. Camerato - Page 15




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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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