No, not the enlisted crew hangout on the Starship Enterprise, rather this is the agent of downfall of IRS’ deficiency case against Luis Carlos Ibarra Cano, T. C. Memo. 2025-65, filed 6/18/25.

LCIC is 400 days late with his petition, and IRS wants summary J tossing the petition for want of jurisdiction. IRS gets that, but not for the reason they wanted (late petition); it’s not sent to last known address, hence defective.

Judge Albert G. (“Scholar Al”) Lauber tells the story.

“Petitioner’s last known address when the Notice of Deficiency was mailed was 220 6th Street, Hempstead, Texas 77445. The Notice was erroneously addressed to him at 2206 TH St. Hempstead, TX 77445-4761. A U.S. Postal Service (USPS) Form 3877, Firm Mailing Book for Accountable Mail, shows that the Notice was sent by certified mail to 2206 TH St. Hempstead, TX 77445.” T. C. Memo. 2025-65, at p. 2.

Usually typos in addresses don’t invalidate SNDs. But this one is over the limit.

“The Notice and the Form 3877 both show an incorrect address for petitioner. The error evidently arose from the transposition of the digit ‘6.’ But this is not a harmless typographical error, as might exist (for example) if the word ‘Street’ had been misspelled. Both documents showed what was almost certainly a nonexistent address. On the record before us, we have no way of knowing how the USPS would have handled delivery of this Notice of Deficiency.” T. C. Memo.  2025-65, at p. 3.

Given a $4K deficiency, is it worth IRS’ while to subpoena an IRS official to testify, especially when LCIC doesn’t even bother to show up for the trial? Of course, LCIC may have known the SND was defectively served, so didn’t waste his time.

IRS argues that the fact LCIC petitioned shows he got the SND timely. Scholar Al doesn’t issue “oh, please”s, but this time he should.

“The fact that petitioner attached to his Petition a copy of the mis-addressed Notice, respondent says, ‘establishes that petitioner received the [N]otice without delay, which proves that the [N]otice is valid for purposes of conferring jurisdiction on the Tax Court.’ We do not reach the same conclusion. Petitioner petitioned this Court… 400 days after the Notice was mailed. This hardly proves that he actually received the Notice ‘without delay.’” T. C. Memo. 2025-65, at p. 4.

Someone somewhere failed to hit the space bar on the keyboard, so “200 6th St” became “2006 TH St.” Looks like they need a proofreader.