- 18 -
Ahrens, supra at 785-786; Coleman v. Commissioner, supra.
Instead, the focus of petitioners’ evidence was that Mr. Spivey
considers mail that he receives to be very important and that
neither petitioner received the final notice of deficiency with
respect to petitioners’ taxable year 1997.
Applying the presumption of official regularity in this
case, we find that on May 5, 1999, respondent mailed by certified
mail to each petitioner the final notice of deficiency with
respect to petitioners’ taxable year 1997 that was addressed to
4425 Northside Drive, Atlanta, Georgia 30327. The parties
stipulated that petitioners resided at that address for the six-
year period preceding the date of the hearing on the parties’
cross-motions. We find that the address to which respondent
mailed the final notice of deficiency with respect to
petitioners’ taxable year 1997 is petitioners’ last known ad-
dress. Although petitioners did not receive that notice, actual
receipt of a notice of deficiency by the taxpayer is not required
to begin the 90-day period within which a taxpayer may file a
petition in the Court. See Keado v. United States, 853 F.2d at
1211-1212; DeWelles v. United States, 378 F.2d 37, 39 (9th Cir.
1967); Estate of McKaig v. Commissioner, 51 T.C. 331, 335 (1968).
We have considered all of the contentions and arguments of
petitioners that are not discussed herein, and we find them to be
8(...continued)
tion to each petitioner.
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