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or without sound basis in fact or law. Woodral v. Commissioner,
supra.
Petitioner argues that respondent had petitioner’s correct
address at the time the notices of deficiency were sent.
Generally, the IRS may not assess a deficiency in tax until
after a valid notice of deficiency has been sent to the taxpayer.
Hyler v. Commissioner, T.C. Memo. 2002-321. For that purpose,
mailing a notice of deficiency is sufficient if it is sent to the
taxpayer at the taxpayer’s “last known address”. Sec. 6212(b).
In determining whether a notice was mailed to a 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”. Alta Sierra Vista,
Inc. v. Commissioner, 62 T.C. 367, 374 (1974), affd. without
published opinion 538 F.2d 334 (9th Cir. 1976).
Petitioner testified that “The only thing I notified [sic]
was when I went for a passport in 1993, and that was submitted to
the Internal Revenue Service with my address.” Petitioner’s
testimony lacks credibility, and we need not accept it. Tokarski
v. Commissioner, 87 T.C. 74, 77 (1986). Petitioner has not
demonstrated that, before the notices of deficiency for the
taxable years 1992 and 1993 were mailed, he provided the Internal
Revenue Service with clear and concise notice of a change of
address. Nor has he shown that, prior to the mailing of the
notices of deficiency, the Internal Revenue Service knew of a
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