John D. Spivey and Pamela K. Spivey - Page 5




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          mail (i.e., certified mail), and the postmark and date of receipt           
          by the Postal Service of PS Form 3877 and the article(s) listed             
          on that form.  After the 90–day notice clerk completed PS Form              
          3877, that form and the article(s) listed on that form were                 
          brought to an office of the Postal Service where an employee of             
          the Postal Service (1) confirmed by signing PS Form 3877 that the           
          article(s) listed on that form was delivered to that office for             
          mailing on the date listed on that form and (2) stamped on that             
          form the date on which the Postal Service received the article(s)           
          listed on that form (i.e., the postmark for those articles).                
               The 90-day notice clerk responsible for the issuance to the            
          taxpayer of a final notice of deficiency placed the initialed               
          copies of that final notice in a suspense file for the 90-day               
          period (90-day suspense period) following the date on which that            
          notice was mailed by certified mail to the taxpayer and during              
          which the taxpayer may file a petition in the Court.  After the             
          expiration of the 90-day suspense period, the 90-day notice clerk           
          noted the status of the case (e.g., whether the taxpayer had                
          filed a petition in the Court, that is to say, whether the case             
          was a docketed case in the Court) in handwriting on the initialed           
          copies of the final notice of deficiency.  One of those initialed           
          copies of the final notice of deficiency containing the handwrit-           
          ten notation regarding the status of the case was then placed in            
          the administrative file pertaining to the taxpayer and the other            
          of those copies was sent to respondent’s quality measurement                




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Last modified: May 25, 2011