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Mail is machine-sorted and dispatched to USPS mail carriers
if the envelope has a bar code, a 5-digit ZIP Code, or a 9-digit
ZIP Code. Mail is processed manually if the envelope does not
have a ZIP Code, if it has a 12- or 13-digit ZIP Code, or if it
is sent by certified mail. Certified mail is processed
separately under an accountability system.
The use of ZIP Codes by mailers is optional.
When the notice of deficiency was mailed to petitioners, the
9-digit ZIP Code address was petitioners’ last known address.
Respondent’s use of the 12-digit ZIP Code address for the
notice of deficiency in the instant case did not affect the
deliverability of the notice of deficiency, because that piece of
mail would in any event have been processed through an
accountability system because it was sent by certified mail.
The notice of deficiency was addressed to petitioners at
their last known address.
OPINION
Respondent contends that this Court does not have
jurisdiction of the instant case because (1) respondent mailed
the notice of deficiency to petitioners’ last known address and
(2) the petition was not filed within 90 days after respondent so
mailed the notice of deficiency. Respondent contends that the
use of the 12-digit ZIP Code address did not prevent delivery of
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Last modified: May 25, 2011