- 15 -
Both notices of FPAA were sent by certified mail.
Before the letters were mailed, an employee of the Austin
Compliance Center prepared a U.S. Postal Service Form 3877
and entered on that form the certified mail number and the
name and address on the envelope of each of the letters.
A postal employee then verified the information on Form
3877 and mailed the letters. The Form 3877 bears a U.S.
Postal Service cancellation stamp which shows the date,
January 28, 1991, and a U.S. Postal Service code for
Austin, Texas, "78760".
On January 28, 1991, an employee of the Austin
Compliance Center also sent, by certified mail, copies
of the notice of FPAA to all 27 partners of the partner-
ship, including Mr. Caldwell and Mr. Denny. Consistent
with respondent's established procedures, one of
respondent's employees at the Austin Compliance Center
obtained a computer-generated document entitled "FPAA
Certified Mail Listing A" which states that "Final
Partnership Administrative Adjustment for the Year(s)
indicated below have been sent to the following Taxpayers:
(Postage Fee Paid by IRS)". There follows a list of the
certified mail number of each notice of FPAA to be sent,
together with the name, address, and Social Security number
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011