The following excerpt is from Agosto v. Tax Com'n, 501 N.E.2d 583, 508 N.Y.S.2d 934, 68 N.Y.2d 891 (N.Y. 1986):
Tax Law 681(a) provides, in pertinent part, that a notice of deficiency "shall be mailed by certified or registered mail to the taxpayer at his last known address". In this case, notwithstanding the minor error in petitioner's address, respondent determined that there was actual receipt in sufficient time to file a petition for redetermination of the deficiencies. This determination may not be disturbed where reasonable inferences from the facts sustain it (Matter of Liberman v. Gallman, 41 N.Y.2d 774, 396 N.Y.S.2d 159, 364 N.E.2d 823).
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