In the facts of this ruling, the question arose as to whether notices of a non-judicial sale could be delivered to the IRS by private delivery services such as United Parcel Service (UPS) or FedEx. The IRS noted that under I.R.C. §7425(c), the notice of sale must be given in writing, by registered or certified mail or by personal service, not less than 25 days prior to sale. The fact that the IRS actually received the documents does not matter. Delivery by private delivery service such as FedEx or UPS didn’t count. C.C.A. 201545025 (Jun. 12, 2015).