Margaret Loughran Webb - Page 4

                                   - NEXTRECORD  -                                    
          of deficiency.3  Each envelope is assigned a certified mail                 
          number.  The 90-day clerk inserts either the original notice of             
          deficiency or a duplicate copy thereof into each envelope to be             
          mailed to the taxpayer.4  The 90-day clerk retains an extra copy            
          of the notice of deficiency for the file maintained by the                  
          Internal Revenue Service (IRS).                                             
               On occasion, the 90-day unit has failed to retain a copy of            
          a notice of deficiency for the IRS file because the 90-day clerk            
          inadvertently mailed all of the copies to the taxpayer.                     
               In addition to preparing notices of deficiency for mailing,            
          the 90-day clerk is also responsible for mailing such notices to            
          taxpayers.  Thus, using the information on the envelopes                    
          containing each notice of deficiency, the clerk completes a                 
          certified mail log using Postal Service Form 3877 (Form 3877).              
          Form 3877 identifies (1) each address to which the notices of               
          deficiency are mailed; (2) the taxable year or years placed in              
          issue by the notices of deficiency; and (3) the article number              
          reflecting the certified mail number of each envelope mailed to             
          the taxpayer.  Then, the clerk delivers the envelopes containing            
          the notices of deficiency, accompanied by Form 3877, to the                 


          3 Because of space limitations on the forms used, a single                  
          notice of deficiency does not place in dispute more than 3                  
          taxable years.                                                              
          4 If the Commissioner's determinations involves more than 3                 
          taxable years (see supra note 3), the 90-day clerk may insert               
          more than one notice of deficiency into the envelope to be mailed           
          to the taxpayer at a particular address.                                    



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Last modified: May 25, 2011