- 18 - notification of a different address.” Sec. 301.6212-2(a), Proced. & Admin. Regs. On September 3, 2002, the IRS received petitioner’s 1999 return, showing his accountants’ Idaho address. For reasons not revealed by the record, respondent did not process this return until November 11, 2002. In the meantime, on November 4, 2002, respondent had received petitioner’s Form 2848, instructing that original notices and other written communications be sent to petitioner at the New Hampshire address and copies be sent to his accountant, Mr. Clayton, at the Idaho address. Respondent contends that notwithstanding his receipt of petitioner’s Form 2848 on November 4, 2002, petitioner’s last known address was his accountants’ Idaho address as shown on petitioner’s 1999 return, which was processed on November 11, 2002, because this was the last return that was “filed and properly processed” before April 22, 2003 (the date on which respondent sent the notice of intent to levy to the Idaho address).8 Respondent seems to suggest that respondent’s processing of petitioner’s 1999 return about a week after 8 On brief, respondent observes in a footnote that petitioner also listed the Idaho address on his timely filed 2002 Federal income tax return. Respondent does not contend, however, that the address shown on petitioner’s 2002 return should establish his last known address as of Apr. 22, 2003, ostensibly because this 2002 return was not processed until May 5, 2003. Accordingly, we give this issue no further consideration.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NextLast modified: November 10, 2007