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staff. At all relevant times, respondent retained the two
initialed copies of the final notice of deficiency that had been
issued to a taxpayer and did not retain any copies thereof that
contained the original signature or a copy of the original
signature of Ms. Runyan (or another representative of respondent)
who signed both the original and the copy of the final notice of
deficiency that were sent to the taxpayer by certified mail. (We
shall refer to all of the foregoing procedures of respondent
relating to the preparation, finalization, and mailing of notices
of deficiency that were in effect at all relevant times for field
cases in respondent’s Atlanta office as respondent’s 90-day
letter procedures.)
At all relevant times, pursuant to the procedures of the
Postal Service that were in effect in its Atlanta offices, if the
addressee of certified mail (or another accountable mail item)
was not available to sign for such mail when the Postal Service
first attempted to deliver it, the Postal Service left a notice,
i.e., U.S. Postal Service Form 3849 (PS Form 3849), in the
addressee’s mailbox, and the certified mail in question was
returned to the Post Office. About five days thereafter, the
Postal Service again attempted to deliver the certified mail in
question to the addressee. If the addressee was not available to
sign for that mail, the Postal Service left another PS Form 3849
in the addressee’s mailbox, and the certified mail in question
was again returned to the Post Office. About ten days after its
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Last modified: May 25, 2011