- 45 - 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 ManualPage: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
Last modified: May 25, 2011