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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