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deficiency was sent to petitioners. The notice of deficiency,
dated October 30, 1998, was mailed to petitioners at the
misspelled Jeremian Drive address, and, subsequently, petitioners
timely petitioned this Court. We assume that petitioners also
received notice of the computational adjustment at the misspelled
Jeremian Drive address.
In Crowell v. Commissioner, 102 T.C. 683 (1994), the Court
held that a taxpayer may contest the validity of a notice of
deficiency for affected items on the ground that the taxpayer’s
partnership items converted to nonpartnership items by virtue of
the Commissioner’s alleged failure to properly notify the
taxpayer of partnership level proceedings.
As stated earlier, we do not find that respondent erred in
failing to notify petitioners about the beginning of the
partnership audit. Furthermore, although the address on the FPAA
was slightly misspelled, petitioners have received mail addressed
to Jeremian (sic) Drive. Insignificant typographical errors in
an address will not prevent a letter or notice from being valid.
See McMullen v. Commissioner, T.C. Memo. 1989-455; Riley v.
Commissioner, T.C. Memo. 1985-231. Therefore, we hold that
respondent notified petitioners of the partnership proceeding as
required by section 6223(a), and the notice of deficiency herein
is valid.
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