Paul J. Kennedy - Page 8




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          certified mail.  The return receipt reflects that respondent                
          received the completed Letter 2797 on July 19, 2001, in Ogden,              
          Utah.  Accordingly, we find that respondent knew, or at the very            
          least should have known on the basis of information mailed to               
          him, that petitioner’s address was the Kost Road address.                   
               In sum, we find that the final notice of intent to levy as             
          well as the NFTL respondent issued with respect to petitioner’s             
          1999, 2000, 2001, 2002, and 2004 tax years were not mailed to               
          petitioner’s last known address and are therefore invalid.  For             
          this reason, we will dismiss this case for lack of jurisdiction.            
               To reflect the foregoing,                                              


                                             An appropriate order will be             
                                        entered dismissing this case for              
                                        lack of jurisdiction on the ground            
                                        that respondent did not send                  
                                        petitioner valid collection notices           
                                        to his last known address.                    

















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