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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