Michael Eisler - Page 3

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          brought under section 6330(d), and petitioner requested that                
          proceedings be conducted pursuant to the provisions of section              
          7463.  Pursuant to section 7463(b), the decision to be entered is           
          not reviewable by any other court, and this opinion shall not be            
          treated as precedent for any other case.                                    
               The issue for decision is whether the notice of                        
          determination was sent to petitioner’s last known address.                  
               When the petition was filed in the instant case, petitioner            
          resided in Philadelphia, Pennsylvania.  Petitioner’s address in             
          Philadelphia, Pennsylvania, is, and at all times pertinent to the           
          instant proceeding has been, in ZIP Code 19111.                             
               The notice of determination was sent to petitioner by                  
          certified mail on June 20, 2006, and addressed to the correct               
          street and number in Philadelphia, but the ZIP Code in the                  
          address was shown as 19114.  As a result of the U.S. Postal                 
          Service’s computer-assisted procedures, that notice of                      
          determination was processed as though the ZIP Code was 19111.               
          Delivery was attempted, unsuccessfully, on June 23, 2006, and a             
          notice of attempted delivery was left at petitioner’s correct               
          address.  The notice of determination was returned to respondent            
          as “unclaimed” on July 8, 2006.                                             
               Petitioner was hospitalized from about June 10 to about July           
          20, 2006, and so did not receive the notice of determination.               

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