Patricia Ann Blocker - Page 8

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          correct address.  See Abeles v. Commissioner, supra; Keeton v.              
          Commissioner, 74 T.C. 377, 382 (1980); Alta Sierra Vista, Inc. v.           
          Commissioner, 62 T.C. 367, 374 (1974), affd. without published              
          opinion 538 F.2d 334 (9th Cir. 1976); Perkins v. Commissioner,              
          T.C. Memo. 2002-174.                                                        
               Petitioner has failed to show that she provided clear and              
          concise notification of a change from the Roydon Drive address.             
          As to petitioner’s contention that respondent should have used              
          the address listed on the Forms W-2 for 1989, we stated in                  
          Farnham v. Commissioner, T.C. Memo. 1991-642, that a requirement            
          that the Commissioner use addresses shown on such documents:                
               would not only impose an unreasonable administrative                   
               burden on respondent to record every address for every                 
               taxpayer, but * * * would cause uncertainty by                         
               requiring respondent to use an address which the                       
               taxpayer did not communicate to him and which the                      
               taxpayer did not clearly tell respondent to use.  * * *                
          Id.  See also Stroupe v. Commissioner, T.C. Memo. 1998-380;                 
          Thiele v. Commissioner, T.C. Memo. 1994-33.                                 
               Another question in this case is whether the IRS should have           
          exercised diligence and located an additional address for                   
          petitioner after the statutory notice of deficiency was returned            
          undelivered.  Whether the Commissioner has exercised reasonable             
          care and diligence is a question of fact.  Frieling v.                      
          Commissioner, 81 T.C. 42, 49 (1983).  The relevant facts are                
          those known before the notice of deficiency was mailed, such as             
          return of letters sent to the taxpayer on earlier dates.  See               

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