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deficiency (the 12-digit ZIP Code address) differed from the last
known address only in that the former included three additional
digits at the end of the ZIP Code.
The unrebutted testimony of a USPS employee who has
management responsibility for, and extensive experience with, the
USPS’s ZIP Code system makes it plain that the three additional
digits at the end of the ZIP Code would not have had any effect
on the deliverability of the notice of deficiency. This
testimony is buttressed by the parties’ stipulation of
petitioners’ receipt of a June 1997 letter (the CP-2000) that had
been addressed to the 12-digit ZIP Code address, and the parties
stipulation of petitioners’ receipt of a May 1998 letter (from
respondent’s Taxpayer Advocate) that had been addressed to the
12-digit ZIP Code address.
Thus, although the three additional digits at the end of the
ZIP Code were not properly part of petitioners’ last known
address, these digits did not affect the deliverability of mail
to petitioners. That is, the three additional digits would not
have affected the USPS’s processing of mail, and mail which
included the three additional digits made its way in a timely
manner to petitioners’ mailbox both before and after the October
22, 1997, notice of deficiency. Under these circumstances, it
would be an exaltation of trivia over both form and substance to
hold that the three additional digits affect the status of the
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Last modified: May 25, 2011