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 42

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             required by section 6223(a)(2) within the time required by               
             section 6223(d)(2).                                                      
                  The record contains sufficient evidence to find that                
             the notice of FPAA was mailed to each notice partner on                  
             January 28, 1991.  At trial, respondent introduced the                   
             testimony of Mr. Norstrud, the Appeals Officer, who                      
             described the general procedures used in respondent's                    
             Dallas office to mail notices of FPAA to a tax matters                   
             partner and notice partners, and described the steps that                
             he took in this case to prepare the FPAA package, including              
             the duplicate notices of FPAA, and to send the FPAA package              
             to the Austin Compliance Center where the notices of FPAA                
             were to be dated and mailed.  Mr. Norstrud testified that                
             in due course thereafter he received from the Austin                     
             Compliance Center copies of the duplicate notices of FPAA                
             which had been stamped "January 28, 1991", and mailed to                 
             the tax matters partner.  Mr. Norstrud also testified that               
             he received from the Austin Compliance Center the "FPAA                  
             Certified Mail Listing A", described above, listing the                  
             name and address of each of the 27 notice partners to whom               
             the notice of FPAA had also been mailed.  Respondent                     
             introduced the FPAA Certified Mail Listing through the                   
             testimony of Mr. Norstrud and a representative of the Ogden              
             Service Center who was the custodian of that document.                   






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