- 16 - undeliverable, forwarding order expired. Petitioner asserts that he never received the notices, and at trial he and his wife testified regarding their various addresses. In particular, petitioner acknowledged that he wrote and signed the January 22, 1999, letter communicating the West Deer Valley address. He also failed to identify any subsequent communication providing the Internal Revenue Service with a superseding address. Ms. Lehmann testified explicitly that no superseding letter had been sent to supply new or updated information. Thus, the notices of deficiency were sent in a manner in compliance with, and valid under, section 6212 and corresponding regulations,7 requiring that a notice of deficiency be sent to a taxpayer’s last known address. Sec. 6212(a) and (b)(1). Concerning issues bearing on receipt for purposes of section 6330, petitioner initially stated that West Deer Valley was his address as of January 22, 1999. Then he said he probably moved at about that time. Next, he testified that it had been over 8 years since he and his wife had lived at either the West Deer Valley address or the East McRae Way address. Finally, he stated explicitly that they had “been living at our address we’re at now since 1996.” 7 See supra note 3.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011