Arthur Tuverson, Cynthia Tuverson v. Commissioner Internal Revenue Service

891 F.2d 296 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Arthur TUVERSON, Cynthia Tuverson, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. No. 89-70174. United States Court of Appeals, Ninth Circuit. Submitted Nov. 6, 1989. * Decided Dec. 4, 1989. Before ALARCON, O'SCANNLAIN, and LEAVY, Circuit Judges. 1 MEMORANDUM ** 2 The Internal Revenue Service (IRS) must give notice to the taxpayer before it may assess or collect any deficiency. 26 U.S.C. § 6213 (a). The taxpayer may, within 90 days after the mailing of the notice, petition the Tax Court for redetermination of the deficiency. 26 U.S.C. § 6213 (a). A notice of deficiency is valid, even if it is not received by the taxpayer, if it is mailed to the taxpayer's "last known address." I.R.C. § 6212(b)(1); King v. CIR, 857 F.2d 676, 680 (9th Cir.1988). 3 Recently, this circuit has restated what comprises a taxpayer's "last known address": 4 We recognized in [ United…