Patricia Ann Blocker - Page 9

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          Mulder v. Commissioner, 855 F.2d 208 (5th Cir. 1988), revg. T.C.            
          Memo. 1987-363.  In Pomeroy v. United States, 864 F.2d 1191, 1195           
          (5th Cir. 1989), the Court of Appeals for the Fifth Circuit                 
          stated:  "The relevant statutes simply require that the                     
          deficiency notice be mailed to the taxpayer's last known address,           
          not that it be received."  The Code does not require remailing              
          the notice, and nothing in the statute suggests that respondent             
          would be obligated to take additional steps to effectuate                   
          delivery if the notice is returned.  Monge v. Commissioner, supra           
          at 33-34.  A notice that is returned undelivered is still valid             
          as long as it was sent to the last known address.  Stroupe v.               
          Commissioner, supra.  Thus, respondent was not required to                  
          investigate further when the notice of deficiency was returned              
          undelivered.  See Monge v. Commissioner, supra at 33-34; Snow v.            
          Commissioner, supra.                                                        
               We have considered the other arguments of the parties, and             
          they are irrelevant and/or lack merit.                                      
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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