- 42 - 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.Page: Previous 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 Next
Last modified: May 25, 2011