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receiving the Form 2848 caused petitioner’s last known address to
revert to the Idaho address shown on that return. We disagree.
In the first instance, respondent has offered no explanation
why petitioner’s 1999 return, which the IRS received on September
3, 2002, was not processed until November 11, 2002. According to
the Commissioner’s revenue procedure, “a return will be
considered properly processed after a 45-day processing period
which begins the day after the date of receipt of the return by
the Internal Revenue Service Center.” Rev. Proc. 2001-18, sec.
5.02(1), 2001-1 C.B. 708, 710. It appears that this 45-day
processing period for petitioner’s 1999 return would have expired
before respondent received the Form 2848. Hence, pursuant to the
revenue procedure, it would appear that petitioner’s 1999 return
should be considered as having been processed before respondent
received the Form 2848. Assuming, then, that petitioner’s last
known address before he filed the Form 2848 was the Idaho address
as shown on his 1999 return, Form 2848 provided respondent “clear
and concise” notification of a change of address to the New
Hampshire address. See Hunter v. Commissioner, T.C. Memo. 2004-
81. Petitioner’s New Hampshire address thus became his last
known address, notwithstanding respondent’s belated processing of
petitioner’s 1999 return.
More fundamentally, we reject respondent’s suggestion that
pursuant to section 301.6212-2(a), Proced. & Admin. Regs., “clear
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