under the notice prong of the Fifth Amendment due process clause and the statute itself, whether the IRS notice means what it says – as the 3rd, 9th, and 11th Circuits recognized and the D.C. Circuit previously agreed – that the 30 days runs from "the date of this letter," or whether it means what the D.C. Circuit held in this case: that the 30 days runs from the date of IRS' mailing of the letter, a date undisclosed to and unknown by Petitioner

Whether the IRS notice means what it says - that the 30 days runs from 'the date of this letter,' or whether it means the 30 days runs from the date of IRS' mailing of the letter