- 17 -
Commissioner, supra at 91.
On the record before us, we have found the existence of a
final notice of deficiency with respect to petitioners’ taxable
year 1997. The record also contains a PS Form 3877 relating to
that final notice of deficiency, which was properly completed and
initialed by one of respondent’s 90-day notice clerks and signed
by a representative of the Postal Service. We conclude on the
instant record that the PS Form 3877 in the record raises a
presumption of official regularity in favor of respondent. See
Keado v. United States, supra; United States v. Zolla, supra;
United States v. Ahrens, supra; Coleman v. Commissioner, supra.
Pursuant to that presumption, the PS Form 3877 in question by
itself is sufficient, absent evidence to the contrary, to estab-
lish that on May 5, 1999, respondent mailed to each petitioner by
certified mail the final notice of deficiency with respect to
petitioners’ taxable year 1997 that was addressed to 4425
Northside Drive, Atlanta, Georgia 30327.
We conclude that petitioners have failed to introduce
evidence that rebuts the presumption of official regularity
raised by the PS Form 3877 in question. In this regard, peti-
tioners offered no evidence that respondent failed to adhere to
respondent’s 90-day letter procedures.8 See United States v.
8Nor have petitioners offered any evidence that the Postal
Service failed to adhere to the Postal Service certified-mail
procedures in attempting to deliver the certified mail in ques-
(continued...)
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