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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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