Last known address.

• Author: Laffie, Lesli S.
• Position: IRS proposed regulations

Proposed regulations (REG-104939-99) define "last known address" for purposes of mailing deficiency and other notices, statements and documents to a taxpayer's last known address. The definition is consistent with Barbara Abeles, 91 TC 1019 (1988), acq.; a last known address would be the address that appears on the taxpayer's most recently filed and properly processed Federal tax return, unless the IRS is given clear and concise notification of a different address.

In the absence of a more recent address, the proposed rules would permit the IRS to use as a last known address one obtained from the U.S. Postal Service (USPS).The IRS could also consult a third-party source for the taxpayer's most current address.

Beginning in May 2000, the IRS will refer to the USPS's National Change of Address (NCOA) database to obtain a last known address. Prop. Regs. Sec. 301.6212-2 would apply to other notices, statements and documents mailed by the IRS to a taxpayer's last known address under the Code or regulations.

The computerized NCOA database obtains change-of-address information from USPS Form 3575, Official Mail Forwarding Change of Address Form. Such address changes are retained for 36 months. The Martinsburg Computing Center would access the database annually to update all taxpayer address records maintained in the IRS's automated master file. Due to IRS system limits, if taxpayers file jointly, but...