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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 jurisdiction
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