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of the notice of deficiency were then produced. Mr. Pierce would
next sign the original and copies of the notice of deficiency on
behalf of the appropriate IRS official. The original and one
copy of the notice of deficiency were mailed to the taxpayer.
Two copies of the notice of deficiency were retained in the
taxpayer's administrative file.
After a notice of deficiency was completed, IRS employee
Dusty Rhoades was responsible for preparing the envelope in which
the document was to be mailed and inserting the document into
that envelope. Mr. Pierce and Mr. Rhoades worked alongside one
another. Before the envelope was sealed, a series of checks took
place in order to ensure the integrity of the process.
Because a notice of deficiency is sent by certified mail,
each one contains a unique certified mailing number which is
placed on the first page of the document. The mailing of each
notice of deficiency is recorded on U.S. Postal Service Form
3877. The form contains the name and address of the taxpayer(s),
the certified mailing number, and the year(s) for which the
notice was issued. The form is postmarked on the date of mailing
and signed by the Postal Service employee who received the items.
Mr. Pierce personally prepared a notice of deficiency
addressed to petitioners for the year 1992. The procedures
outlined above were followed in connection with the preparation
of that notice. All the relevant records maintained by either
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Last modified: May 25, 2011