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deficiency had been issued and mailed, it would have been claimed
by them or someone authorized to do so on their behalf.
Petitioners request that we find that neither notice of
deficiency was issued and mailed merely because neither was
claimed. Petitioners' failure to claim other items sent to them
by certified mail during the same period, however, undermines
their argument on the point. Furthermore, to accept petitioners'
contention would require us to reject not only the testimony of
the IRS employee actually responsible for the preparation and
mailing of the relevant notices of deficiency, but the testimony
of the U.S. Postal Service employee as well.
A review of the records that typically reflect when a notice
of deficiency is prepared and mailed to a taxpayer indicates that
two notices of deficiency for the year 1987 were mailed to
petitioners on May 3, 1996. We reject petitioners' implicit
suggestion that respondent and the U.S. Postal Service fabricated
records to make it appear that the notices were mailed on May 3,
1996. Accepting petitioners' contention implies some form of
conspiracy between respondent and the U.S. Postal Service a
proposition that we are unwilling to accept on the basis of the
record before us.
We are satisfied from the evidence that on May 3, 1996, two
notices of deficiency for the year 1987 were issued and sent by
certified mail to petitioners. One of the notices of deficiency
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