- 46 -
(CCH), sec. 7(11)62.2, at 22,863-5. Respondent's
procedures call for the preparation and use of an FPAA
Certified Mail Listing, rather than U.S. Postal Service
Form 3877, to document the fact and date of mailing of the
notice of FPAA to notice partners. Compare PCS Handbook,
supra sec. 524 with 5 Administration, Internal Revenue
Manual (CCH), sec. 7(11)62.2, at 22,863-5.
We also reject petitioners' argument that respondent
should have introduced "green cards" to show receipt of
the notice of FPAA by a notice partner, or U.S. Postal
Service Forms 3849 to document attempted delivery of the
notice. Section 6223(a) provides that "the Secretary shall
mail" the notices required by that section. The statute
does not require the use of certified mail. Respondent's
procedures require notices of FPAA to be mailed by
certified mail, but there is nothing in respondent's
procedures that calls for the use of a green card or return
receipt. Similarly, if respondent had introduced U.S.
Postal Service Form 3849 to show attempted delivery of
certified or registered mail with respect to the notice of
FPAA mailed to one or more of the notice partners in this
case, that would be further evidence of the mailing of the
notice of FPAA. However, the absence of U.S. Postal
Service Form 3849 from the record does not reasonably
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