- NEXTRECORD -
Petitioner contends that no notice of deficiency exists for
the taxable years 1989 through 1991, as evidenced by the fact
that respondent has been unable to produce a copy of any notice
for those years. Further, petitioner contends that if such
notice of deficiency exists, notices of deficiency for the
taxable years 1989 through 1993 were never mailed to her.
Finally, petitioner contends that even if notices of deficiency
for the taxable years 1989 through 1993 were mailed to her, such
notices were not mailed to her last known address.
As explained more fully below, we hold: (1) Respondent
presented sufficient evidence to prove the existence of a notice
of deficiency for the taxable years 1989 through 1991; (2)
respondent mailed notices of deficiency for the taxable years
1989 through 1993 on January 24, 1995; and (3) notices of
deficiency were mailed to petitioner at her last known address.
Respondent bears the burden of proving that she mailed
notices of deficiency to petitioner and the date on which the
notices were mailed. Pietanza v. Commissioner, supra at 736;
August v. Commissioner, 54 T.C. 1535, 1536 (1970). Respondent is
required to introduce evidence showing that notices of deficiency
were properly delivered to the Postal Service for mailing.
Coleman v. Commissioner, 94 T.C. 82, 90 (1990); see Cataldo v.
Commissioner, 60 T.C. 522 (1973), affd. per curiam 499 F.2d 550
(2d Cir. 1974). The act of mailing may be proven by evidence of
respondent's mailing practices corroborated by testimony or
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