Ruben G. Hinojos - Page 5

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          The statutory notices are thereafter generally brought to the               
          mailroom at the center for delivery to the post office.                     
               On days when the tax examiner is unable to deliver the                 
          statutory notices directly to the post office, the tax examiner             
          will wait for the USPS daily mail carrier (USPS carrier) to                 
          arrive.  At that time, the USPS carrier is then given the                   
          statutory notices as well as the Form 3877.  The USPS carrier               
          "double checks" all of the statutory notices with the names on              
          the Form 3877 to verify that the names on the statutory notices             
          match those on the Form 3877.  Thereafter, the USPS carrier signs           
          and dates the Form 3877.  The Form 3877 is not stamped with a               
          postmark by the USPS carrier because the USPS will not allow mail           
          carriers to carry postmark rubber stamps.  This routine occurs in           
          the normal course of business, on average, twice a week.                    
               The Form 3877 introduced into evidence in this case                    
          indicates that a statutory notice was sent by the Albuquerque               
          Center to petitioner at the Sunland Park, New Mexico, address for           
          tax years 1990, 1991, and 1992.  The Form 3877 also indicates               
          that statutory notices were sent to 12 other taxpayers.  The Form           
          3877 indicates that the receiving employee of the USPS                      
          postmaster, in this case the USPS carrier, received 13 pieces of            
          mail that day that were to be sent by certified mail, return                
          receipt.  The Form 3877 is signed by the USPS carrier and hand              

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