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notice is sent to the taxpayer’s representative. McDonald v.
Commissioner, supra at 752-753; Allen v. Commissioner, supra at
117. Sending copies of the statutory notice to representatives
named in a power of attorney is merely a courtesy to the
taxpayer, not an obligation of the IRS, and in no way affects the
mailing requirements of section 6212. McDonald v. Commissioner,
supra at 753; Houghton v. Commissioner, 48 T.C. 656, 661 (1967).
Accordingly, the notice of deficiency is valid despite Mr. Rehm’s
failure to receive a copy.
Petitioners’ remaining arguments relate to their underlying
tax liability for 2001. The record clearly demonstrates,
however, that respondent properly mailed them a notice of
deficiency for 2001 on October 27, 2004. Respondent attached to
his motion a copy of the notice of deficiency and a copy of the
U.S. Postal Service Form 3877, confirming that a copy of the
notice was mailed to each petitioner on October 27, 2004. The
record does not contain any evidence that the notice of
deficiency was ever returned to respondent nor have petitioners
denied receiving it. Moreover, Mrs. Bond admitted at the face-
to-face conference held on December 29, 2005, and in a January
27, 2006, letter to Officer Heidle that petitioners received the
October 27, 2004, notice of deficiency. Accordingly, we conclude
that because petitioners received a statutory notice of
deficiency, petitioners are precluded under section 6330(c)(2)(B)
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