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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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