- NEXTRECORD -
Form 3877 provides sufficient proof of mailing); United States v.
Zolla, 724 F.2d 808 (9th Cir. 1984) (where Government destroyed
all copies of the notice of deficiency, the Government proved
that the "notices and assessments were properly made" based on
Form 3877 and the absence of contrary evidence); United States v.
Ahrens, 530 F.2d 781 (8th Cir. 1976) (where all copies of the
notice of deficiency were lost, existence and mailing of the
notice of deficiency were proved based on Form 3877 and
supplemental evidence corroborating such form).
Finally, we address petitioner's contention that the notices
of deficiency were not mailed to petitioner at her last known
address. Petitioner argues that the notices are invalid because
they were mailed to Box 176A-2, Box 176AZ, and Box 76A-2, rather
than to Box 176-A2. We find the error in the notice of
deficiency addressed to petitioner at Box 176A-2 to be an
inconsequential error that does not compromise the validity of
the notice of deficiency. See Occean v. Commissioner, T.C. Memo.
1991-439 (where a notice of deficiency mailed to 765 Amsterdam
Ave 2G, rather than to 765 Amsterdam Ave Apt 2G, the notice was
valid because taxpayers did not prove a delay in delivery);
McMullen v. Commissioner, T.C. Memo. 1989-455 (deficiency notice
was mailed to taxpayer's last known address, notwithstanding a
mistake in the spelling of the street name in the address to
which the notice was mailed); Kohilakis v. Commissioner, T.C.
Memo. 1989-366 (error in address of deficiency notice was so
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