Questão jurídica principal
Whether the objection against the federal direct tax assessment was filed in time after valid notification.
Decisão extraída
The objection was late because the assessment entered the taxpayer's sphere of influence well before 2002-06-13 and he had not arranged proper receipt of mail in Switzerland.
Fundamentação extraída
Notification is complete when the act enters the addressee's sphere of influence. The taxpayer still used the Swiss address, had not notified a change of address, and had not validly appointed a Swiss representative, so he had to expect tax mail there.