PREGERSON, Circuit Judge:
The Tax Court dismissed Eve C.W. Wallin's (Wallin's) petition for redetermination of tax deficiency as untimely. The Internal Revenue Service (IRS) sent a notice of tax deficiency to Wallin's former address although it had notice that Wallin had moved. Wallin did not receive the deficiency notice within the time limit allowed to file a petition for redetermination. The Tax Court ruled that the IRS exercised reasonable diligence in searching...
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