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section 6212(b), an improperly addressed notice of deficiency
remains valid under section 6212(a) if it is actually received in
sufficient time to permit the taxpayer to file a timely petition
for redetermination. Mulvania v. Commissioner, 81 T.C. 65, 67-69
(1983), affd. 769 F.2d 1376 (9th Cir. 1985).
The determination of whether a taxpayer’s ability to file a
timely petition has been prejudiced by an improperly addressed
notice is factual in nature. Looper v. Commissioner, 73 T.C.
690, 699 (1980). In general, the cases in which we have held
that an improperly addressed notice of deficiency was actually
received with sufficient time to permit the taxpayer to file a
timely petition for redetermination have involved receipt with at
least 30 days left in the filing period. See, e.g., Mulvania v.
Commissioner, supra at 68 (74 days remaining); Bowers v.
Commissioner, T.C. Memo. 1991-609 (69 days remaining); Fileff v.
Commissioner, T.C. Memo. 1990-452 (60 days remaining); George v.
Commissioner, T.C. Memo. 1990-147 (52 days remaining); Bulakites
v. Commissioner, T.C. Memo. 1998-256 (45 days remaining); Loftin
v. Commissioner, T.C. Memo. 1986-322 (30 days remaining); Eger v.
Commissioner, T.C. Memo. 1984-325 (30 days remaining). In a
situation where a notice was actually received with only 17 days
left in the filing period, we held that the taxpayer was
prejudiced by the improperly addressed notice because he did not
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