Brian J. Laborde, T. C. Memo. 2026-74, filed 8/20/26, had three (count ’em, three) mailing addresses during the four (count ’em, four) years this case concerns. IRS hit Brian with a couple TFRP Letters 1153 for those years, and Brian doesn’t contest those. Nor does he contest the NFTL that followed.

He does contest the NITLs, saying those weren’t sent to his last known address. And the AO at Appeals who gave the Section 6330(c)(1) verification that all procedures were followed was a trifle conclusory, never stating how reached the conclusion that NITLs were mailed to last known address.

As we all know, that’s not waivable, even if not raised by Brian’s trusty rep on paper (or electrons) or at the CDP. Statute says Appeals shall verify.

Judge Adam B. (“Sport”) Landy traces Brian’s peripatetic wanderings all over The Big Easy, seeing where he says he lived and when and what he put on his tax returns and any other clear and concise notifications he gave IRS.

But the AO did none thereof, so this case gets remand for Determination Number Four.

Takeaway- Practitioner, add to your Form 12153 and your petition boilerplate failure to comply with Section 6330(c)(1) verification.