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and the signed or initialed copies thereof to the support staff
of 90-day notice clerks. In accordance with respondent’s 90-day
letter procedures, on May 5, 1999, one of the 90-day notice
clerks properly prepared and initialed a PS Form 3877 relating
to, inter alia, the final notice of deficiency with respect to
petitioners’ taxable year 1997 (PS Form 3877 in question). The
PS Form 3877 in question showed that on May 5, 1999, respondent
mailed by certified mail a final notice of deficiency with
respect to petitioners’ taxable year 1997 to each petitioner at
4425 Northside Drive, Atlanta, Georgia 30327. The PS Form 3877
in question also showed that on the same date, respondent mailed
by certified mail (1) a final notice of deficiency with respect
to Perimeter’s taxable year ended January 31, 1997, to Perimeter
and (2) a copy of that notice to Paul Frederick Kelly (Mr. Kelly)
to whom Perimeter had granted a power of attorney. The PS Form
3877 in question contained a Postal Service stamp and the signa-
ture of a Postal Service employee, which showed that on May 5,
1999, a Postal Service office located in Atlanta, Georgia,
received that form and the articles listed thereon.
The 90-day notice clerk who prepared the PS Form 3877 in
question placed the initialed copies of the final notice of
deficiency with respect to petitioners’ taxable year 1997 in a
suspense file for the 90-day suspense period. Respondent did not
retain any copies thereof that contained the original signature
or a copy of the original signature of Ms. Runyan. After the
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