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The only thing clear is that she moved many times. She contends
that she lived with her former husband for a few months in 1988,
that she lived on Westerland Avenue at the time of her divorce,
and that she lived at the Jeanetta address in Houston commencing
in 1988. Respondent contends, without persuasive evidence in the
record, that petitioner rented the Roydon Drive address beginning
in 1989 and then provided that address to the IRS. Given
petitioner’s failure to communicate with the IRS, it is more
likely that the Royden Drive address was shown on a return filed
for 1988. In any event, prior to 1993, the Roydon Drive address
was the address for petitioner reflected in IRS records, which
were not changed again until 1998.
Petitioner also claims that the statutory notice should have
been mailed to a Bering Drive address, which was used on a letter
sent to petitioner in August 1993. There is no explanation in
the record as to how that address would have become known to the
IRS. The Bering Drive address was not the address shown on any
return filed by petitioner, and there is no evidence as to
whether or when she lived at that address. The Bering Drive
address thus cannot be considered her last known address.
Petitioner contends that the IRS should have mailed the
notice of deficiency or remailed the notice of deficiency to the
Jeanetta address shown on the Forms W-2 for 1989 sent to the IRS
by third-party payers of the income. Respondent argues that
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