- 44 - 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 partnersPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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