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Postal Service Form 3877 shows an address of "P.O. Box 400" for
the Federal Correctional Institute, Three Rivers, rather than the
correct address of "P.O. Box 4000".
Based upon the record, including the notice of deficiency
attached to petitioner's petition which bears an address of "P.O.
Box 4000", we are satisfied "P.O. Box 400" is a typographical
error on the Postal Service Form 3877, and that the notice of
deficiency was in fact sent to the Federal Correctional
Institution, Three Rivers, at P.O. Box 4000. Petitioner's other
arguments in his opposition to respondent's motion are at odds
with the facts he alleged in the petition he filed with the
Court. In his petition, petitioner states that his "legal
address" is "FCI Three Rivers, P. O. Box 4000, Three Rivers,
Texas 78701." He further states in his petition that he is
"incarcerated in the Federal Correctional Institution at Three
Rivers, Texas".
Considering all the facts and circumstances, we need not
resolve whether respondent mailed the notice of deficiency to
petitioner's last known address. As explained below, we conclude
that, even assuming arguendo that the Federal Prison Camp,
Tilden, address constituted petitioner's last known address, the
notice of deficiency was delivered to petitioner at that address
without prejudicial delay. Although a deficiency notice properly
mailed to a taxpayer's last known address provides the
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Last modified: May 25, 2011