-5- the addressee.” Zenco Engg. Corp. v. Commissioner, 75 T.C. 318, 323 (1980), affd. without published opinion 673 F.2d 1332 (7th Cir. 1981). Further, it is clear that in general, and in the absence of evidence to the contrary, compliance with certified mail procedures raises a presumption of official regularity in delivery and receipt with respect to notices sent by the Commissioner. See United States v. Zolla, 724 F.2d 808, 810 (9th Cir. 1984); United States v. Ahrens, 530 F.2d 781, 784-785 (8th Cir. 1976); Clough v. Commissioner, 119 T.C. 183, 187-188 (2002). Respondent’s records show that petitioner was sent a final notice of intent to levy by certified mail to an address that petitioner admits has been his address for 10 years. Petitioner claims that he did not know of the attempted delivery, but he has offered no proof to support his claim. Petitioner argues that his situation is akin to that of Buffano v. Commissioner, supra, where the Court dismissed the case on the ground that the taxpayer was not issued a valid collection notice because the Commissioner did not send the collection notice to the taxpayer’s last known address. See also Kennedy v. Commissioner, T.C. Memo. 2008-33. In this case, the notice of intent to levy was sent to petitioner’s last known address. Therefore, the Court finds that respondent issued petitioner a valid notice of intent to levy, but petitioner did not receive it either because of his deliberate refusal to accept the letterPage: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008