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expiration of the 90-day suspense period, the 90-day notice clerk
noted the status of the case in handwriting on the initialed
copies of the final notice of deficiency with respect to peti-
tioners’ taxable year 1997, and one of those initialed copies
containing that handwritten notation was sent to respondent’s
quality measurement staff.
The Postal Service followed the Postal Service certified-
mail procedures in attempting to deliver to each petitioner the
certified mail addressed to each of them that was listed on the
PS Form 3877 in question. On May 27, 1999, after having unsuc-
cessfully attempted to deliver that certified mail to each
petitioner, the Postal Service returned that mail to respondent.
Petitioners did not receive the final notice of deficiency with
respect to their taxable year 1997 that respondent mailed to each
of them by certified mail on May 5, 1999.
Respondent’s 90-day letter procedures also were followed in
preparing, finalizing, and mailing by certified mail on May 5,
1999, to Perimeter a final notice of deficiency with respect to
its taxable year ended January 31, 1997.3 Mr. Spivey, as presi-
dent of Perimeter, received that final notice, which the PS Form
3877 in question showed was mailed to Perimeter by certified mail
on May 5, 1999. Mr. Kelly received a copy of that final notice,
3In accordance with respondent’s 90-day letter procedures,
respondent’s quality measurement staff retained an initialed copy
of that notice, which contained a handwritten notation of the
status of the case.
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Last modified: May 25, 2011