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Mexico, U.S. Postal Service, and delivery to petitioner was
attempted.
At trial, the Postmaster of Anthony, New Mexico, Bob Moulds
(Mr. Moulds) stated that a ZIP Code is not required for proper
delivery of an item, but does expedite delivery, and is
considered part of the address once added. See Watkins v.
Commissioner, supra. Mr. Moulds testified that the incorrect ZIP
Code in the address used to mail the notice of determination did
not affect the proper delivery of the notice to petitioner.
Mr. Moulds stated that an item mailed from Austin, Texas, such as
the notice of determination, would not have had sufficient time
to be sent to the incorrect ZIP Code used in mailing the notice,
and then be sent to Anthony, New Mexico, in the span of 4 days.
Mr. Moulds testified that he believed the notice of
determination was sent from Austin, Texas, to Albuquerque, New
Mexico, then to Las Cruces, New Mexico, and finally to Anthony,
New Mexico, which was the normal course of mail, despite the
error in the ZIP Code. The tracking information presented to the
Court appears to confirm that the incorrect ZIP Code did not
adversely affect delivery of the notice of determination.
Mr. Moulds also testified as to the usual procedure followed
for certified mail. Certified mail is scanned at the U.S. Postal
Service Office and treated as an accountable. Initially, the
mail carrier takes the accountable with him or her to the address
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