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where the error is so minor that it did not prevent delivery of
the notice. Pickering v. Commissioner, supra (citing McMullen v.
Commissioner, T.C. Memo. 1989-455 and Kohilakis v. Commissioner,
T.C. Memo. 1989-366). This Court has specifically held that an
error in the ZIP Code constitutes an inconsequential error and
does not affect the last known address. Gam v. Commissioner,
T.C. Memo. 2000-115; Pickering v. Commissioner, supra; Watkins v.
Commissioner, T.C. Memo. 1992-6; Boothe v. Commissioner, T.C.
Memo. 1986-361.
In the instant case, the Court concludes that the notice of
determination concerning collection action was mailed to
petitioner’s last known address, and the incorrect ZIP Code is an
inconsequential error. The address used to mail the notice of
determination is the same address listed by petitioner in his
correspondence with respondent and on Form 12153.6 The notice of
determination correctly listed petitioner’s name, street address,
city and State, but incorrectly provided the ZIP Code.7 See
Pickering v. Commissioner, supra; Boothe v. Commissioner, supra.
Despite the error, within 4 days of respondent’s mailing the
notice of determination, it was received by the Anthony, New
6Petitioner did not file a Federal tax return for any of the
taxable years 1995 through 2004.
7It is noteworthy that petitioner incorrectly listed his own
ZIP Code in correspondence with respondent.
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