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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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