Rose C. Pfeffer, of the Estate of Emma Apisdorf, Deceased v. Commissioner of Internal Revenue

Notice of the 1958 income tax deficiency against Emma Apisdorf was sent by registered mail to her last known address in New York — the address she gave on her tax return — on May 20, 1958, but was returned undelivered, since she had died the year before in Paris. On August 11, 1958, the Commissioner sent a second letter, addressed to her in care of her daughter, Mrs. Pfeffer, at the latter’s address, pointing out, however, that there was no statutory requirement of such remailing. This letter was received by Mrs. Pfeffer, to whom letters testamentary were issued later. The petition for review…