John D. Spivey and Pamela K. Spivey - Page 8




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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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