Thomas W. Hunter, Jr. - Page 11

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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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