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 45

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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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