John D. Spivey and Pamela K. Spivey - Page 4




                                        - 4 -                                         
          respectively) and initialed the remaining two copies thereof                
          (initialed copies).  Thereafter, Ms. Runyan sent the signed                 
          original and the signed copy, as well as the initialed copies, of           
          the final notice of deficiency to a support staff of clerks known           
          as 90-day notice (or suspense) clerks (90-day notice clerks).               
               Pursuant to respondent’s procedures that were in effect at             
          all relevant times for the issuance of notices of deficiency for            
          field cases in respondent’s Atlanta office, one of the 90-day               
          notice clerks stamped on the signed original, the signed copy,              
          and the initialed copies of the final notice of deficiency the              
          date on which the notice was to be mailed by certified mail to              
          the taxpayer and wrote by hand on that original and those various           
          copies the final date on which that taxpayer may file a petition            
          in the Court.  Pursuant to those procedures, the 90-day notice              
          clerk also completed and initialed U.S. Postal Service (Postal              
          Service) Form 3877 (PS Form 3877), an official mailing list form            
          of the Postal Service that was prepared and used by a sender for            
          mailing so-called accountable mail items (e.g., items mailed by             
          certified mail or registered mail).  In order to complete PS Form           
          3877 with respect to the mailing by certified mail of a final               
          notice of deficiency, the 90-day notice clerk indicated on that             
          form the name(s) and address(es) of the addressee(s) of such                
          certified mail, the article number(s) of such mail, the nature of           
          the article(s) being mailed (i.e., notice of deficiency), the               
          year to which the article(s) being mailed pertained, the type of            




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Last modified: May 25, 2011