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of each addressee. In this case, the list shows that 29
notices of FPAA were mailed to the 27 partners of the
partnership. In the case of two partners, the list shows
that the notice of FPAA was mailed to a second address.
The last page of the FPAA Certified Mail Listing A
contains the statement: "Total No. of pieces received at
P.O. 29 ." It also states "Postmaster (per name of
receiving employee) Date: ." Following
the word "Date" is a date stamp and initials. The date
stamp is not fully legible, but the legible portion reads
"Austin, Texas" and bears the U.S. Postal Service code
"78760" and the date "January, 1991".
The Austin Compliance Center transmitted copies of
the notices of FPAA that had been stamped with the date,
January 28, 1991, to the Appeals Office in Dallas, Texas,
along with the FPAA Certified Mail Listing A. Mr. Norstrud
received those documents in due course after January 28,
1991.
At some time after January 28, 1991, Mr. Caldwell
wrote to Mr. Norstrud and complained that the mailing of
the notice of FPAA was "outside the statute of limitation
[sic]." Mr. Caldwell's letter states as follows:
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