§4243

ress information. The 45-day period, even counting from the time the Form 2848 was filed, would have ended well before Jan. 28, 1998–- the date that the IRS sent out the notices of deficiency. - 13 - address. 1 Audit, Internal Revenue Manual (CCH), sec. 4243.2(6)(b) (as in effect January 1999) (if mail undeliverable, IRS should “check all possible sources in the case files”).8 Instead, the stipulated facts show no effort to redeliver the notices even after respondent began using petitioner’s Hen

internal procedures allow for other than written “clear and concise” notice of a change of address if such notice is received by, or provided to, respondent during the course of an income tax examination. See 4 Examination, Internal Revenue Manual, sec. 4243.1(2)(b) (Nov. 14, 1994); see also Westphal v. Commissioner, T.C. Memo. 1992-599. During the course of the examination of petitioners’ 1996 joint return, petitioner notified respondent of a change of address over the telephone, and petitione

Section 4241 imposed an excise tax on club dues, and section 4243 provided an exemption from the excise tax for members’ payments for the construction or reconstruction of capital improvements.