- 11 - that petitioner’s case is different: His form directed only copies go to his representatives, and merely informed respondent of his address, without saying that he wished the new address to supplant the old. But we reject the assertion that a valid change-of-address notification must use language equivalent to “please note that this is a change of address.” As petitioner points out, no such glaring notification exists on a tax return, or on the power-of- attorney forms given effect in Rizzo and Johnson. We also think that respondent’s position overlooks a more general theme in the case law; namely, that the IRS is chargeable with knowing the information that it has readily available when it sends notices to taxpayers. As courts have repeatedly observed, the steady advance of technology continues to lighten the IRS’s burden in searching its own records for current address information. Union Tex. Intl. Co. v. Commissioner, 110 T.C. 321, 334 (1998). Petitioner is thus right in noting that address information on the Form 2848 is not mere surplusage. The IRS asks for that information and solicits taxpayer’s directions on what address should be used for original and duplicate notices. This strongly implies that respondent will actually incorporate the information on the form into its databases and use the information when sending notices to a taxpayer’s “last known address.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011