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envelope containing the letter of transmittal and the photocopied
returns with original signatures for 1981-95. Petitioner closed
the flap on the envelope that contained those returns and secured
the metal clasp. Petitioner did not show or identify the
contents of the envelope to the second person. Petitioner gave
the envelope to the second person.
C. Respondent’s Processing of the Returns
1. Respondent’s Procedures
In 1997, deliveries for Harrington were usually processed by
Susan Arczynski (Arczynski), the assistant district director’s
secretary. Her usual practice was to stamp the time and date
when she received an item and to use the director’s routing stamp
on the item if there was room to do so. If there was no room for
the director’s routing stamp, Arczynski’s usual practice was to
staple to the item a small routing slip containing the same
information as the routing stamp. She always used a routing slip
instead of the stamp if the item was a tax return.
Arczynski was at work on February 21, 1997. At trial, she
could not remember whether she had received Allnutt’s package of
returns for the years 1981-95.
Personnel in the District Director’s office usually directed
persons who asked where to file tax returns to the walk-in area
of the taxpayer services office on the first floor.
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