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taxpayer at the taxpayer's last known address, the relevant
inquiry “pertains to * * * [the Commissioner’s] knowledge rather
than to what may in fact be the taxpayer's most current address.”
Frieling v. Commissioner, supra at 49.
Respondent mailed the notice of deficiency to the address
listed on petitioner's 2000 return--the last return filed by
petitioner prior to the mailing of the notice on September 19,
2001. Consequently, the notice of deficiency was mailed to
petitioner at her last known address unless petitioner can
demonstrate: (1) She provided respondent with clear and concise
notice of a change of address; or (2) prior to the mailing of the
notice of deficiency, respondent 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;
Keeton v. Commissioner, supra at 382; Alta Sierra Vista, Inc. v.
Commissioner, 62 T.C. 367, 374 (1974), affd. without published
opinion 538 F.2d 334 (9th Cir. 1976).
There is nothing in the record to suggest that petitioner
gave respondent clear and concise notice of any change of
address, nor is there anything in the record to suggest that
respondent knew about any change of address.4 Finally, we
4 The fact that petitioner’s residence may have been
renumbered for purposes of the “911” emergency system does not,
in and of itself, constitute notice to respondent that
petitioner’s address may have changed. This is particularly true
(continued...)
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