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(misaddressed notice of deficiency valid where taxpayers filed a
timely petition). An error in the address used in mailing a
notice of deficiency is inconsequential where the error is so
minor that it would not prevent delivery of the notice. See
McMullen v. Commissioner, T.C. Memo. 1989-455; Kohilakis v.
Commissioner, T.C. Memo. 1989-366.
In Watkins v. Commissioner, T.C. Memo. 1992-6, the Court
sustained the validity of a notice of deficiency mailed to an
address that included an incorrect ZIP code. The Court reasoned
as follows:
According to the [United States Postal Service
Domestic Mail Manual], the address may include the name
of the recipient, the rural route and box number, the
city, and State. It is recommended that ZIP code be
used. However, the ZIP code number is not a
requirement for proper delivery, but is for the
convenience of the Postal Service and is helpful to
ensure prompt delivery. In our view, the typing of the
incorrect 5-digit ZIP code on the notice and mailing
envelope is a de minimis error not fatal to a notice of
deficiency. * * *
Unlike the present case, the record in Watkins included the
testimony of the rural letter carrier that the incorrect ZIP code
did not cause confusion in the attempted delivery of the notice.
The letter carrier testified that she left two notices of
certified mail (Form 3849) in the taxpayers' mailbox in an effort
to deliver the notice of deficiency.
Nevertheless, the principle that an incorrect ZIP code
constitutes an inconsequential error with respect to the mailing
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