-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.
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Last modified: May 25, 2011