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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.
Background
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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Last modified: November 10, 2007