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effectively results in actual notice is what is
apparently contemplated by the legislative plan.
Clodfelter v. Commissioner, 527 F.2d 754, 756 (9th Cir. 1975),
affg. 57 T.C. 102 (1971).
As previously discussed, respondent mailed the notice of
deficiency to petitioner at 2162 Ingleside Avenue on November 15,
1995. The notice was forwarded to the 2411 Ingleside Avenue
address one day later. However, consistent with Terry McMahon's
directions, all mail addressed to 2411 Ingleside Avenue,
including the notice of deficiency, was forwarded to Mail Boxes,
Etc. Delivery of the envelope bearing the notice was accepted by
an employee of Mail Boxes, Etc., on November 24, 1995. The
notice of deficiency was later forwarded by Mail Boxes, Etc., to
petitioner in Spokane, Washington.
Notwithstanding the circuitous route by which the notice of
deficiency arrived at Mail Boxes, Etc., it is evident that the
mailing of the notice of deficiency to 2162 Ingleside Avenue did
not materially affect the delivery of the notice to petitioner.
The notice was forwarded to and arrived without apparent delay at
2411 Ingleside Avenue, the address which petitioner has
identified as her last known address. See Yusko v. Commissioner,
supra at 810; see also Needham v. Commissioner, T.C. Memo. 1993-
440. The notice was destined to be forwarded again to Mail
Boxes, Etc., even if it had been addressed to petitioner at 2411
Ingleside Avenue. The notice of deficiency was actually received
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