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evidence of respondent’s mailing practices corroborated by direct
testimony. Coleman v. Commissioner, supra at 90. A U.S. Postal
Service Form 3877, Acceptance of Registered, Insured, C.O.D. and
Certified Mail, reflecting Postal Service receipt represents
direct documentary evidence of the date and fact of mailing.
Id.; Magazine v. Commissioner, 89 T.C. 321, 324, 327 (1987).
Where the existence of the notice of deficiency is not in
dispute, a properly completed Form 3877 by itself is sufficient,
absent evidence to the contrary, to establish that the notice was
properly mailed to a taxpayer. United States v. Zolla, 724 F.2d
808, 810 (9th Cir. 1984); Coleman v. Commissioner, supra at 91.
In this case, respondent produced a copy of the certified
mailing list for January 6, 2004, which bore a date stamp from
the Los Angeles Post Office of January 6, 2004. The list shows
petitioner’s name, North Market Street address, taxpayer
identification number, and the article tracking number of the
notice of deficiency. The certified mailing list submitted by
respondent is similar to, and appears to perform the same
function as, Form 3877. See Stein v. Commissioner, T.C. Memo.
1990-378. However, in this case the certified mailing list is
incomplete because it does not contain any indication of the
number of items received by the Los Angeles Post Office and is
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