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Petitioner’s mail box is physically located on a rural road with
three other neighbors’ mail boxes and is in front of 860
Broadmoor, which is two houses down from petitioner’s house. The
notice of attempted delivery was recorded in Chaparral, New
Mexico, 88081. Additionally, the track and confirm receipt
reflects that a second notice of attempted delivery was delivered
on April 11, 2005, at 4:26 p.m., and was recorded in Anthony, New
Mexico, 88021. The track and confirm receipt provides that the
notice of determination was delivered in Chaparral, New Mexico,
88081, on April 13, 2005, at 9:44 a.m., which delivery date was
more than 30 days after the mailing of the notice of
determination.4
The notice of determination was delivered to a contract
postal unit located in the General Store in Chaparral, New
Mexico. In response to the second notice of attempted delivery,
petitioner requested that his certified letter be delivered to
the General Store. It is unclear from the record the exact date
that petitioner retrieved the notice of determination from the
General Store. It would have occurred, however, sometime after
4A taxpayer has 30 days after the issuance of the notice of
determination concerning collection action to petition this Court
for a redetermination. See sec. 6330(d)(1). The notice of
determination was mailed to petitioner on March 10, 2005. Taking
into account an intervening weekend, the 30th day thereafter was
Monday, Apr. 11, 2005. See sec. 7503.
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