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initial attempt to deliver the certified mail in question, the
Postal Service again attempted to deliver that certified mail to
the addressee. If the addressee was not available to sign for
the certified mail in question, the Postal Service left a third
and final PS Form 3849 in the addressee’s mailbox, and that
certified mail was returned to the Post Office. Thereafter, on
or about the 15th day after the initial attempted delivery by the
Postal Service of the certified mail in question, the Postal
Service sent that mail to its claims and inquiry section. That
section then logged the undelivered certified mail in question
into its records as unclaimed and returned that mail to the
sender. (We shall refer to the above-described procedures in the
Atlanta offices of the Postal Service in attempting to deliver
certified mail as the Postal Service certified-mail procedures.)
Ms. Runyan prepared and finalized a notice of deficiency
with respect to petitioners’ taxable year 1997 in accordance with
respondent’s 90-day letter procedures. In that final notice,
respondent determined a deficiency in, and a penalty under
section 6662 on, petitioners’ Federal income tax (tax) for 1997
of $64,864 and $12,973, respectively.
In accordance with respondent’s 90-day letter procedures,
after Ms. Runyan finalized the notice of deficiency with respect
to petitioners’ taxable year 1997, copies of that notice were
made, the original and those copies were returned to Ms. Runyan
for her signature or initials, and she sent the signed original
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Last modified: May 25, 2011