Misdelivery alone, however, should not distinguish consequential from inconsequential error. Even perfectly addressed mail at times suffers misdelivery. Where an address, ex ante, enables delivery to the intended destination, then that address is proper and any error is inconsequential. The Post Office itself promulgates standards for deliverable mail in the “Domestic Mail Manual of the Postal Service” (Mail Manual). 39 C.F.R. § 111.5 (2001). The Mail Manual provides, inter alia, that a deliverable address need not contain a zip code at all. Id. at A010. Similarly, other courts considering this type of issue have held that lack of a zip code or an incorrect zip code will not preclude mail from being “properly addressed.” See, e.g., Pickering v. Comm’r, 75 T.C.M. (CCH) 2152 (1998) (<HOLDING>); Int’l Television Film Prod., Inc. v. Comm’r,
holding that an incorrect zip code does not render an otherwise proper address improper holding that whether an incorrect zip code on a notice of sale is properly addressed is a question of fact holding that service was not defeated by an address with an incorrect zip code holding a missing zip code to be an inconsequential error that does not defeat a notice of deficiency holding that an inaccurate zip code does not render an address improper for purposes of texas rule of civil procedure 5