Not Judge Cathy (“NCY = No Cognomen Yet”) Fung. She forewent applying Loper-Bright to the Rev. Proc. 2010-16 change-of-address pronunciamento (see my blogpost “Addressing Loper-Bright,” 7/10/25), and now when USPS tells her there’s no difference when the same zip-plus-four covers two separate FL municipalities, she tosses Jason Darby, Docket No. 7964-24, filed 12/31/25, for filing 156 days after IRS mailed the SND to Pembroke Pines, but with the same zipcode as Hollywood.

Jason claims the SND wasn’t send to his last known address, because his last return showed Hollywood, not Pembroke Pines.

But the zipcode was the same.

“To show that respondent’s address error would not have affected proper mail delivery, respondent provided the Declaration from a USPS official. The Declaration confirmed that a letter mailed to the Pembroke Pines address would be delivered to the same destination in Hollywood, Florida 33025. Thus, we are satisfied that respondent mailed the Notice to petitioner’s last known address, whether it was mailed to the Pembroke Pines address or the same address in Hollywood, Florida 33025.” Order, at pp. 6-7.