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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 letter
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