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16 J. Tax Prac. & Proc. 33 (2014-2015)
The Last Known Address: A Joint Effort between the IRS and the U.S. Postal Service

handle is hein.journals/jtaxpp16 and id is 101 raw text is: LARRYJONES is a Partner in the Dallas office of Townsend & Jones, L.L.P., and focuses his practice on tax controversy matters. He is also Director of the SMU Dedman School of Law Tax Clinic and teaches FederalTax Procedure at the law school. Larry can be reached at larry@ tjtax[aw.com. RACHEL MULTER MICHALEWICZ is a student attorney at SMU Dedman School of Law and Chief Counsel in the Tax Clinic. The Last Known Address: Ajoint Effort Between the IRS and the U.S. Postal Service By LarryJones and Rachel Multer Michalewicz Larry Jones and Rachel Mu[ter Micha[ewicz analyze the doctrine of clear and concise notification of a change in address as been developed by the Tax Court. Introduction Certain notices that inform taxpayers of important statutory rights are required by the Internal Revenue Code (the Code) to be sent to the taxpayer's last known address.' Reg. §301.6212-2(a) defines last known address as the address that appears on the taxpayer's most recently filed and properly processed Federal tax return, unless the Internal Revenue Service (IRS) is given clear and concise notification of a different address. According to Reg. §301.6212-2(b)(1), address information about a taxpayer from a third party is not a clear and concise notification of a different address. The regulation provides an exception for addresses obtained from the U.S. Postal Service (USPS). Using the USPS's National Change of Address (NCOA) database, the IRS is able to update a taxpayer's address in certain circumstances.2 The IRS is provided with weekly updates of changed addresses from the NCOA database. In the IRS's records of an individual taxpayer, an address updated through the NCOA database is given a unique Document Locator Number (DLN) of XX-2-63-995- 99999-Y3 Using this, a practitioner can determine if a taxpayer's address records were updated through the NCOA database. The IRS compares the taxpayer's address information in their records with the records in the NCOA database.4 If the taxpayer's name and last known address -2014 L. JONES AND R. MULTER MICHALEWICZ APRIL-MAY 2014

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