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Virginia, address. Stone neglected to advise petitioner of
receipt of that notice. Petitioner seeks to disavow some
communications sent to Stone. His inconsistent positions
concerning her authority and her misrepresentations of her
capacity are not attributable to respondent. See Lefebvre v.
Commissioner, T.C. Memo. 1984-202, affd. 758 F.2d 1340 (9th Cir.
1985). Any confusion was created by petitioner and his
representative, and their communications cannot be characterized
as clear and concise.
We are unpersuaded by petitioner’s contentions that, on
other occasions, he or Stone had provided clear and concise
notification of his new Portola Valley address before the 1995
and 1997 deficiency notices were mailed. Those occasions
involved persons who were either with the Office of the Taxpayer
Advocate, the Special Procedures Office, or the Collection
Division. Petitioner’s use of a new address in dealings with
persons who were not involved with the issuing of deficiency
notices did not require them to compare the address petitioner
used to the last known address otherwise on file. United States
v. Zolla, 724 F.2d at 811; see also Rev. Proc. 90-18, 1990-1 C.B.
491.
Another notification of a new address, petitioner argues,
came when IRS received an unsigned Form 4868 seeking an automatic
extension of time within which petitioner might file his 1998
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