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court found--at the Government’s insistence--that the taxpayer’s
Form 2848 established a “last known address” different from the
one appearing on the taxpayer’s most recently filed return. And
in Johnson v. Commissioner, 611 F.2d 1015, 1020 (5th Cir. 1980),
revg. and remanding T.C. Memo. 1977-382, the Fifth Circuit
similarly held that a Form 2848 is sufficient to change a last
known address, even if the IRS later loses the form. We
ourselves have repeatedly held that a power-of-attorney form
directing the IRS to send all original documents to a
representative is an adequate notification of a change of
address: Maranto v. Commissioner, T.C. Memo. 1999-266; Elgart v.
Commissioner, T.C. Memo. 1996-379; Honts v. Commissioner, T.C.
Memo. 1995-532.
This case would seem only a bit different--here petitioner
directed that copies be sent to his accountants, and it is he
rather than respondent who is claiming that a Form 2848
effectively makes a change of address. Petitioner suggests
neither of these distinctions makes a difference. In his view,
for a filing to change a “last known address” it must only be
(1) clear and concise, (2) a notification, (3) and show a
different address from the last one sent to the IRS. He then
insists that his October 1998 power-of-attorney form meets all
three requirements. It was “clear and concise” because the Form
2848 was the IRS’s own form; it was a notification because it was
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