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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.
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