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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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