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documentary evidence. Coleman v. Commissioner, supra, at 90.
Form 3877, reflecting Postal Service receipt, represents direct
documentary evidence of the date and fact of mailing. Magazine
v. Commissioner, 89 T.C. 321, 324, 327 (1987). Absent evidence
to the contrary, a properly completed Form 3877 is highly
probative evidence that notices of deficiency were mailed on the
postmark date to the taxpayers listed on the form. Cataldo v.
Commissioner, supra at 524.
In the instant case, respondent introduced into evidence a
completed and postmarked Form 3877. Such form certifies that
notices of deficiency for the taxable years 1989 through 1993
were mailed to petitioner on January 24, 1995. Additionally,
respondent presented the testimony of Ms. Brown, who described
the established procedures surrounding the preparation and
mailing of the notices of deficiency. Based on these procedures,
we find it highly unlikely that Form 3877 would reflect that
notices of deficiency were mailed for specific taxable years if
notices did not in fact exist for such years. Similarly, we find
it highly unlikely that entries regarding notices of deficiency
would appear on Form 3877 if such notices were not actually
mailed. Notably, the information on Form 3877 was copied from
the envelopes containing the notices of deficiency that were
mailed to petitioner, and the information on those envelopes was
copied directly from the actual notices of deficiency enclosed
therein.
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