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Commissioner, supra at 773. The exceptions to the taxpayer's
burden to provide clear and concise notification have occurred
where the Commissioner had at his disposal specific information
concerning the whereabouts of an incarcerated taxpayer. See
DiViaio v. Commissioner, 539 F.2d 231 (D.C. Cir. 1976); Keeton v.
Commissioner, 74 T.C. 377 (1980); O’Brien v. Commissioner, 62
T.C. 543 (1974).
Here, petitioner does not allege, and we do not find, that
he notified respondent that he wished any correspondence to be
sent to him at his place of incarceration prior to respondent's
mailing the notice of determination on January 30, 2003. While
petitioner informed the settlement officer that he would be going
to jail, this information "was not of sufficient clarity and
precision to fulfill petitioner's duty of providing clear and
concise notice of a definite change of address." Tirado v.
Commissioner, supra. Moreover, there is no allegation or
suggestion that respondent had some other means of knowing the
specifics of petitioner's incarceration, such that petitioner
might be relieved of his duty to provide clear and concise
notification of any change in address. Keeton v. Commissioner,
supra, is instructive. In that case, the Commissioner had
participated in the prosecution that led to the taxpayer's
conviction for Federal tax crimes. Thus, we concluded that the
Commissioner knew the taxpayer was in Federal prison and could
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