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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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