Fletcher H. Hyler - Page 22

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          Federal income tax return.  The Form 4868, which was mailed                 
          sometime prior to August 18, 1999, used the Portola Valley                  
          address.  However, the Form 4868 does not indicate that it is               
          intended as a notification of a change of address.  Under these             
          circumstances, the submission of a Form 4868 does not constitute            
          the requisite notification that the address it contains is a new            
          address for the taxpayer.  Monge v. Commissioner, 93 T.C. 22, 32            
               We conclude that petitioner’s haphazard use of his new                 
          address did not constitute "clear and concise written                       
          notification".  He fell short of placing the examination division           
          on notice that the Woodside address, the address appearing on his           
          last-filed return, was not his last known address.  We conclude             
          that the notices of deficiency for 1995 and 1997, which were                
          mailed to the Woodside address, were valid.                                 
          Due Process Was Not Offended by Efforts To Collect Petitioner’s             
          Tax Liabilities                                                             
              The IRS has published a list of policies regarding the                  
          administration of the internal revenue laws in the Internal                 
          Revenue Manual.  One section of the Manual describes the filing             
          of notices of tax lien, as follows:                                         
                   (1) Notices of lien generally filed only after                     
               taxpayer is contacted in person, by telephone or by                    
               notice:  A notice of lien shall not be filed, except in                
               jeopardy assessment cases, until reasonable efforts                    
               have been made to contact the taxpayer in person, by                   
               telephone or by a notice sent by mail, delivered in                    
               person or left at the taxpayer's last known address, to                

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