Margaret Loughran Webb - Page 5

                                   - NEXTRECORD  -                                    
          Postal Service.  Once at the post office, a postal clerk verifies           
          the information on Form 3877 with the information reflected on              
          the envelopes containing the notices of deficiency.  If the                 
          information is accurate, the postal clerk stamps Form 3877 with a           
          U.S. Postal Service stamp indicating the current date and the               
          post office location.                                                       
               In the instant case, respondent introduced into evidence the           
          Form 3877 completed by a 90-day clerk supervised by Ms. Brown.              
          The Form 3877 indicates that, on January 24, 1995, duplicate                
          notices of deficiency involving the taxable years 1989 through              
          1993 were mailed by certified mail to petitioner at the following           
          four addresses:  (1) Route 1, Box 176A-2, Ivanhoe, Texas 75447;             
          (2) Route 1, Box 176AZ, Ivanhoe, Texas 75447; (3) Route 1, Box              
          76A-2, Ivanhoe, Texas 75447; and (4) 146 West 16th, Plano, Texas            
          75075.  The Form 3877 is postmarked January 24, 1995, by the                
          Postal Service in Dallas, Texas.                                            
               Respondent has been unable to produce a copy of a notice of            
          deficiency for the taxable years 1989 through 1991.  However,               
          respondent has produced a copy of a notice of deficiency for the            
          taxable years 1992 and 1993.  Ms. Brown identified the notice of            
          deficiency for 1992 and 1993 as one originating from her unit.              
               The Postal Service facility in Ivanhoe, Texas, is a small              
          post office that has approximately 270 post office box customers.           
          Donna Russell (Ms. Russell) was the postmistress of the Ivanhoe             






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