- 4 - Respondent later mailed by certified mail a notice of deficiency for 1988, 1992, and 1993 to petitioner at 705 El Medio on July 8, 1996, and petitioner received that notice of deficiency in a timely fashion. The petition herein is timely with respect to that notice of deficiency. The envelope in which the subject notice of deficiency was mailed by respondent was received in evidence. It is a standard business-sized window envelope. Across the window was a scrawling apparently made by a felt-tip pen. Above the window in blue ballpoint pen are the numbers “705”. On the right-hand side of the envelope is a stamp providing for entries on four lines identified as “Name”, “First Notice”, “Second Notice”, and “Return”. Entries on or near these four lines are respectively “MLJ”, “6-5-96", “6-10", and “6-20". In addition, the envelope bears the stamps “unclaimed” and “return to sender” and indications that the envelope was received by the Los Angeles District of the Internal Revenue Service on June 25, 1996, and by suspense control of Internal Revenue Service on July 3, 1996. Respondent presented the testimony of Anthony Ficklin (Mr. Ficklin), a delivery supervisor of the U.S. Postal Service, who had been in that position approximately 8 to 9 years and had been at the branch of the Pacific Palisades, California, post office handling petitioner’s mail delivery for about 5 years. Mr. Ficklin was familiar with the procedures for handling certifiedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011