Frank Tavano v. Commissioner of Internal Revenue

In Brafman v. United States, 384 F.2d 863 (5th Cir.1967), our predecessor circuit wrote in dictum that a notice of tax deficiency sent to a taxpayer by the Internal Revenue Service need not be signed in order to be valid. Id. at 865 n. 4 (citing Commissioner v. Oswego Falls Corp., 71 F.2d 673, 677 (2d Cir.1934), and 9 Jacob Mertens, Jr., Federal Income Taxation § 49.186 (1965)). 1 We now expressly so hold. Accordingly, we affirm the judgment of the tax court holding appellant Tavano liable for tax deficiencies and additions. 2

I

On April 5, 1988, Tavano received from the Commissioner of…