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so, the fact that the notice of deficiency was not received by
petitioners is of no consequence. See King v. Commissioner,
supra; United States v. Zolla, 724 F.2d 808, 810 (9th Cir. 1984).
Lastly, petitioners argue that respondent's failure to
remail the notice of deficiency violated certain provisions of
the Internal Revenue Manual. In this regard, petitioners point
out in their brief that respondent is required to mail duplicate
original notices of deficiency "where there might be some doubt
as to the correctness of the last known address." Respondent
apparently did exactly that in this case. Nevertheless,
petitioners go on to argue that if "a notice of deficiency is
returned to the respondent, IRM 4462.1(5) instructs revenue
agents to remail notices of deficiency to the correct addresses."
(Emphasis added.) The section of the manual cited by petitioners
states:
(5) If a notice of deficiency is returned to the
District Director because of an incorrect address, it
will be remailed to the correct address by certified
mail; in such cases, the date of remailing is the
effective date of the notice.
Returned mail should put the sender on notice that the letter
might have been incorrectly addressed. The above-referenced
manual provision was no doubt designed to cover those situations
and implies that respondent should recheck his records in order
to ascertain the taxpayer's correct address. In this case,
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