-9- During the approximately 1-year period starting with the date when respondent processed petitioner’s 2001 return reporting the 4302 Callahan address and ending with the date when respondent processed petitioner’s 2002 return reporting the 912 Sir James Bridge address, petitioner’s last known address was 4302 Callahan.4 Cf. Abeles v. Commissioner, 91 T.C. 1019 (1988); sec. 301.6212-2, Proced. & Admin. Regs. (effective January 29, 2001) (absent “clear and concise notification of a different address”, a taxpayer’s last known address is the one on the most recently filed and processed tax return, with exceptions for updated addresses obtained by respondent from an information bank of the Postal Service). During that period, respondent sent both the 30-day letter and the Letter 1912(DO) to petitioner at 4302 Callahan. While petitioner speculates that respondent should have known that petitioner did not then live there because respondent had previously been informed that petitioner and Davis had sold the property, we do not agree. The mere fact that petitioner and Davis sold 4302 Callahan on February 23, 2000, does not necessarily mean that petitioner never lived there afterwards. Such is especially so given the fact that Campbell, petitioner, and petitioner’s wife who joined with him on the 2001 4 When respondent processed petitioner’s 2002 return, petitioner’s last known address changed to 912 Sir James Bridge. Respondent mailed the notice of deficiency to that address in January 2004.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011