Questão jurídica principal
Whether the taxpayers' objection to the 2006 reassessment and penalty decisions was filed in time
Decisão extraída
The objection period began when the decisions were placed in the taxpayers' mailbox on 2008-10-10, so the objection filed on 2008-11-12 was late.
Fundamentação extraída
For ordinary postal delivery, service is effective once the document enters the addressee's sphere of control, here the mailbox/post office box; actual later reading is irrelevant. The authority proved delivery by the postal tracking record and surrounding circumstances.