- 9 - however, the notices of deficiency were not returned to respondent because of incorrect addresses. The notices of deficiency were correctly addressed. They were returned because petitioners did not claim either of them. Consequently, the above-referenced manual provision has no application. Because respondent did not violate his own directive, we need not consider whether any such violation would have had any consequences. Under the circumstances, it would have taken little effort on respondent's part simply to remail the notices of deficiency to the same addresses. Nevertheless, respondent's failure to do so does not invalidate the notices of deficiency. Neither the statute, the relevant cases, nor respondent's internal procedures impose any obligation upon respondent to remail a notice of deficiency that has been properly mailed to a taxpayer but returned unclaimed. In this case, a notice of deficiency for the year 1987 was issued and sent to petitioners at their last known address by certified mail on May 3, 1996. That being so, under the circumstances, the statutory period for filing a petition with this Court in response to that notice of deficiency expired on August 1, 1996. Sec. 6213(a). The petition in this case was filed on June 16, 1997, which is well beyond the period prescribed for doing so. Consequently, we have no jurisdictionPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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