Fletcher H. Hyler - Page 19

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               acquired in any fashion.  We decline to require the IRS                
               to do that. * * * it would impose an unreasonable                      
               administrative burden on the IRS.  * * *                               
          In this case, the notices of deficiency were mailed to the                  
          Woodside address listed on petitioner's 1998 return--the last               
          return filed by petitioner prior to the mailing of the notices in           
          July and August 1999.  Consequently, the notices of deficiency              
          were mailed to petitioner at his last known address, unless                 
          petitioner can show otherwise.                                              
               Petitioner has not demonstrated that, before the 1995 and              
          1997 notices of deficiency were mailed, he provided the IRS with            
          clear and concise notice of a change of address.  Nor has he                
          shown that, prior to the mailing of the notice of deficiency, the           
          IRS knew of a change in petitioner's address and did not exercise           
          due diligence in ascertaining petitioner's correct address.  See            
          Abeles v. Commissioner, supra; Alta Sierra Vista, Inc. v.                   
          Commissioner, supra at 374.                                                 
               Petitioner maintains that he provided notification of his              
          Portola Valley address on several occasions.  None of those                 
          occasions, however, provided the clear and concise notice needed            
          to charge the IRS in the summer of 1999 with knowledge that                 
          Portola Valley was the last known address.                                  
               Petitioner principally urges that the IRS received clear and           
          concise notice of an address change when, in 1998, Rausch was               
          conducting an examination of petitioner’s 1995 return.  During              

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