- 7 - Rehm did not receive a copy of the October 27, 2004, notice of deficiency. Petitioners allege that because they executed a power of attorney placing Mr. Rehm in charge of all matters relating to their 2001 tax year, respondent erred by not sending him a copy of the notice.4 Petitioners’ argument is without merit. The power of attorney designated Mr. Rehm as petitioners’ representative and authorized him to receive copies of communications sent by respondent to petitioners. However, the power of attorney specified that respondent would send all original communications to petitioners. Under like circumstances we have held that the failure to mail a copy of the notice of deficiency to a taxpayer’s representative is not fatal to the validity of the notice. McDonald v. Commissioner, 76 T.C. 750, 753 (1981); Allen v. Commissioner, 29 T.C. 113, 117 (1957). Section 6212 requires only that the Secretary mail the notice of deficiency by certified or registered mail to the taxpayer’s last known address. A notice of deficiency is valid if it is mailed directly to a taxpayer at the taxpayer’s last known address, even if the taxpayer directs that a copy of all communications be sent to the taxpayer’s representative and no copy of the deficiency 4 We shall assume for purposes of this discussion that the Form 2848, Power of Attorney and Declaration of Representative, signed by Mrs. Bond and Mr. Rehm on Oct. 12, 2004, is valid despite petitioner Craig Bond’s failure to sign it.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007