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Northside Drive, Atlanta, Georgia 30327.7 The PS Form 3877 in
question was properly completed and initialed by a representative
of respondent and contained a stamp showing receipt on May 5,
1999, of the items listed on that form by an office of the Postal
Service in Atlanta, Georgia, as evidenced by the stamp of the
Postal Service on the PS Form 3877 in question and the signature
of a Postal Service representative.
A PS Form 3877 reflecting receipt by the Postal Service
represents direct documentary evidence of the date and the fact
of mailing. See Coleman v. Commissioner, supra at 90. A prop-
erly completed and executed PS Form 3877 also reflects compliance
with respondent’s established procedures for mailing deficiency
notices. See Keado v. United States, supra at 1212-1213; Coleman
v. Commissioner, supra. Where the existence of the notice of
deficiency is not disputed, or, as is the case here, has been
established, a properly completed PS Form 3877 by itself is
sufficient, absent evidence to the contrary, to show that the
notice of deficiency was properly mailed to a taxpayer, that is
to say, raises a presumption of official regularity in favor of
respondent. See Keado v. United States, supra; United States v.
Zolla, supra at 810; United States v. Ahrens, supra; Coleman v.
7The PS Form 3877 in question also shows that on May 5,
1999, respondent mailed to Perimeter by certified mail a final
notice of deficiency with respect to Perimeter’s taxable year
ended Jan. 31, 1997, and that on the same date a copy of that
notice was mailed by certified mail to Mr. Kelly to whom
Perimeter had granted a power of attorney.
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