United States v. Edward M. Zolla

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• explaining that a notice is valid when mailed to a taxpayer’s last known address even if the taxpayer did not receive the notice
• observing that United States Postal Service Form 3877 is highly probative and sufficient to establish that a notice and assessment was properly made
• holding PS Forms 3877 “are highly probative, and are sufficient, in the absence of contrary evidence, to establish that the notices and assessments were properly made”
• explaining that the last known address is the one “on [the taxpayer’s] most recent return, unless the taxpayer communicates to the IRS clear and concise notice of a change of address”
• although original copies of notices had been destroyed, certificates sufficed in absence of contrary evidence to establish correctness of notices and assessments
• Postal Form 3877 is highly probative, without contrary evidence, that a notice of deficiency was properly mailed

Source: CourtListener parenthetical corpus (CC0).