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We disagree with petitioners’ arguments and are unpersuaded
by their allegations. The record establishes that petitioners’
last known address for purposes of the notice of deficiency was
the Lawrence address. See United States v. Zolla, 724 F.2d 808,
810 (9th Cir. 1984) (taxpayer’s last known address is the address
that appears on the taxpayer’s most recently filed Federal tax
return, unless the Commissioner is given clear and concise
notification of a different address); Abeles v. Commissioner,
91 T.C. 1019 (1988) (same); see also Lifter v. Commissioner,
59 T.C. 818, 821 (1973) (“taxpayer’s last known address may be
his office rather than his residence”). See generally sec.
301.6212-1(a), Proced. & Admin. Regs. (Commissioner adopts the
rule of Zolla and Abeles, effective Jan. 29, 2001). Given our
finding that petitioners’ most recent Federal tax return before
the issuance of the notice of deficiency listed their mailing
address as the Lawrence address, we conclude that the
Commissioner’s mailing of the notice of deficiency to that
address was appropriate.
As to petitioners’ allegations as to Riley, we find them
unsubstantiated. The record includes neither a copy of Form
2848, Power of Attorney and Declaration of Representative,
designating Mr. Riley as petitioners’ authorized representative
for 1996, nor any other credible evidence establishing a clear
and concise notification to the Commissioner that the Lawrence
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