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in respondent's Dallas, Texas, office, and he explained the
steps taken to mail the notices of FPAA in this case, which
were consistent with respondent's established procedures.
The evidence is sufficient to prove respondent's procedures
for mailing the notice of FPAA to notice partners, and to
prove that those procedures were followed in this case. It
is not necessary for respondent to introduce the testimony
of other persons who recall each step in the process of
mailing the notice of FPAA at issue. See generally
Coleman v. Commissioner, 94 T.C. 82 (1990); Cataldo v.
Commissioner, 60 T.C. 522 (1973); Dorsey v. Commissioner,
T.C. Memo. 1993-182.
Petitioners' assertion that the use of the FPAA
Certified Mail Listing was contrary to respondent's
procedures is incorrect. The FPAA Certified Mail Listing
is a three-part computer-generated form that is used by the
Internal Revenue Service to document the mailing of
notices of FPAA to notice partners. See 1 Audit, Internal
Revenue Manual (CCH), sec. 4227.47, at 7233-20; Partnership
Control System Handbook, 3 Audit, Internal Revenue Manual
(CCH), sec. 524, at 8617, 8617-74 (hereinafter PCS
Handbook). It is similar to U.S. Postal Service Form 3877
which is used to document the mailing of a notice of
deficiency. See 5 Administration, Internal Revenue Manual
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