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return it must be signed by the taxpayer under penalties of
perjury.” Cupp v. Commissioner, 65 T.C. 68, 78 (1975), affd.
without published opinion 559 F.2d 1207 (3d Cir. 1977).
Accordingly, petitioner’s most recently filed “return” at the
time of the mailing of the notice of deficiency for 1997 appears
to be his 1997 return. Cf. King v. Commissioner, supra at 681.
Second, even if the 1998 Form 1040 is considered to be a
subsequently filed tax return, it did not operate to change
petitioner’s last known address for purposes of the notice of
deficiency for 1997. Even though the 1998 Form 1040 was not
signed, respondent processed the 1998 Form 1040. Respondent
entered the 1998 Form 1040 into his computer system on August 9,
1999--5 days after the mailing of the notice of deficiency for
1997. Accordingly, respondent was not aware of a change of
address prior to mailing the notice of deficiency for 1997.
In Williams v. Commissioner, 935 F.2d 1066 (9th Cir. 1991),
affg. T.C. Memo. 1989-439, the taxpayer filed a return showing a
new address on April 15, 1987. This new return, however, had not
been processed by the IRS so as to be available through a
computer inquiry by the agent who sent the notice of deficiency
on June 17, 1987. The U.S. Court of Appeals for the Ninth
Circuit agreed with us that: (1) The reasonable business
requirements of the IRS necessitated time for the processing of
the filed return through its computer facilities in order for the
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