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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
(1989).
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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