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 44

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             mailing.  Finally, petitioners note that there were 27                   
             partners in the partnership and that the FPAA Certified                  
             Mail List shows that 29 notices of FPAA were sent in this                
             case.  According to petitioners, this is an "indication of               
             the unreliability of" the FPAA Certified Mail Listing.                   
             Petitioners argue:  "This one inconsistency is large enough              
             to be sufficient to bar * * * [the FPAA Certified Mail                   
             Listing] as evidence as proof of mailing by itself."                     
                  Each of the questions raised by petitioners regarding               
             the admissibility and probative value of the FPAA Certified              
             Mail Listing is meritless.  Respondent introduced the                    
             subject document, not only through the testimony of a                    
             representative of the Ogden Service Center, but also                     
             through the testimony of Mr. Norstrud.  The representative               
             of the Ogden Service Center stated that he was custodian                 
             of the FPAA Certified Mail Listing.  He explained that                   
             the Ogden Service Center had taken over the duties of the                
             Austin Compliance Center and that the records of the Austin              
             Compliance Center had been transferred to the Ogden Service              
             Center.  He also described respondent's procedures for                   
             mailing the notices of FPAA to notice partners and stated                
             that those procedures are set forth in the Internal Revenue              
             Manual.  Mr. Norstrud also explained respondent's                        
             procedures for mailing notices of FPAA to notice partners                






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