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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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