- 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011