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effect of such an abandonment or withdrawal. Mitteldorfer
Straus, Inc. v. Commissioner, T.C. Memo. 1979-503 (citing
Skaneateles Paper Co. v. Commissioner, 29 B.T.A. 150 (1933));
Holter v. Commissioner, T.C. Memo. 1978-411.
Petitioner agrees that, in 1994 and 1995, her last known
address was the Bay Harbor Island address. We conclude that the
notice of deficiency that was mailed to the Bay Harbor Island
address on December 8, 1994, was properly mailed to petitioner’s
last known address. She has not argued, and there are no facts
in the record that would indicate, that the U.S. Postal Service
mishandled the notice of deficiency mailed to the Bay Harbor
Island address. In fact, petitioner’s counsel explained to the
Court that Pericles G. Nichols died sometime before the December
8, 1994, notice of deficiency was mailed to the Bay Harbor Island
address, and that during this time petitioner had received a
great volume of mail and “she wasn’t paying attention to
everything that was going on”. It seems more likely than not
that the notice of deficiency sent to petitioner’s last known
address was returned undelivered because of petitioner’s refusal
of delivery. As such, respondent has done all he could
reasonably do to provide notice to petitioner. Erhard v.
Commissioner, 87 F.3d 273 (9th Cir. 1996), affg. T.C. Memo. 1994-
344; Patmon & Young Profl. Corp. v. Commissioner, supra at 218.
There is no indication in the record that respondent
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