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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.”
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