Alan Berkun, who was imprisoned for federal crimes and owed restitution to the Internal Revenue Service, challenged the dismissal of his Tax Court petition concerning a notice of intent to levy. The IRS mailed the notice to Berkun’s former home, where an authorized recipient signed the return receipt, while Berkun was incarcerated and had previously supplied the IRS with his prison address. He argued that due process required notice at the prison and that the appeal period should begin when he actually received the notice. The Eleventh Circuit denied the petition for review. The court did not reach those substantive arguments because the Tax Court lacked jurisdiction over the petition as untimely under the statutory filing period. The court also declined to consider Berkun’s legislative-history theory, which he first raised in a motion to vacate rather than in response to the dismissal motion. Published opinions ordinarily resolve legal issues, but this court explained that it published the decision because the notice and jurisdiction questions could deserve attention from the bench and bar.