Margaret Loughran Webb - Page 14

                                   - NEXTRECORD  -                                    
          minor that it would not have prevented delivery); Riley v.                  
          Commissioner, T.C. Memo. 1985-231 (same).  Thus, we find that               
          respondent mailed at least one copy of the notices of deficiency            
          to petitioner at her last known address.                                    
               In any event, the errors in the address of the notices of              
          deficiency mailed to petitioner in Ivanhoe, Texas, were rendered            
          harmless by virtue of the fact that petitioner actually received            
          all three copies of the notices of deficiency.  An erroneously              
          addressed notice of deficiency is valid if the taxpayer receives            
          actual notice of respondent's deficiency determination in a                 
          timely fashion; i.e., without prejudicial delay.  See Mulvania v.           
          Commissioner, 81 T.C. 65, 67-68 (1983) (holding an erroneously              
          addressed notice valid under section 6212(a) where taxpayer                 
          received the notice 16 days after it was mailed); Patmon & Young            
          Professional Corp. v. Commissioner, T.C. Memo. 1993-143, affd. 55           
          F.3d 216 (6th Cir. 1995); Iacino v. Commissioner, T.C. Memo.                
          1992-111 (where a notice of deficiency mailed to 6221 East 42nd             
          Avenue, rather than to 6211 East 42nd Avenue, resulted in actual            
          notice without prejudicial delay, the notice was valid although             
          misaddressed).                                                              
               The record in the instant case reveals that petitioner was             
          presented with the notices of deficiency about a week after they            
          were mailed by respondent.  Petitioner was directly asked by Ms.            
          Russell, the Ivanhoe postmistress, whether petitioner intended to           
          claim her certified mail, and petitioner refused delivery by                




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