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jurisdiction pursuant to section 6330(d)(1). In objecting to
respondent’s motion, petitioners argue that: (1) They did not
receive the June 23, 2000, notice; and (2) the December 14, 2001,
notice offered petitioners a section 6330 hearing for 1998
because it was titled a “Final Notice”.
A. Was the June 23, 2000, Notice Sent to Petitioners’ Last
Known Address?
As noted above, the notice of intent to levy must be given
in person, left at the person’s dwelling or usual place of
business, or sent by certified or registered mail to the person’s
last known address. Secs. 6330(a)(2) and 6331(d)(2); secs.
301.6330-1(a), 301.6331-2(a)(1), Proced. & Admin. Regs. The
regulations under sections 6330 and 6331 reference section
301.6212-2, Proced. & Admin. Regs., to define “last known
address”. Secs. 301.6330-1(a), 301.6331-2(a)(1), Proced. &
Admin. Regs. Under section 6212, in general, the Commissioner is
entitled to treat the address on a taxpayer’s most recent tax
return as the taxpayer’s last known address, unless the taxpayer
has given “clear and concise notification of a different
address.” Kennedy v. Commissioner, 116 T.C. 255, 260 n.4 (2001);
Abeles v. Commissioner, 91 T.C. 1019, 1035 (1988); sec. 301.6212-
2(a), Proced. & Admin. Regs.
Although respondent did not enter the June 23, 2000, notice
into the record, as proof of its mailing respondent provided
petitioners’ Form 4340, Certificate of Assessments, Payments, and
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