Wayne Caldwell Escrow Partnership, Roy Dimon, John and Mary Schuenemann, Joseph and Louise O'Neal, Charles and Lovetta Niven, Chalton and Cynthia Thomas, Partners Other Than the Tax Matters Partner - Page 15

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                  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              








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