- 8 -
deficiency clerk, and is stamped by the U.S. Postal Service
August 11, 1999. At trial, Pam Butler, respondent’s clerk who
delivered the notice of deficiency to the post office,
corroborated the information on the Form 3877. The information
was also corroborated by John Bohan, respondent’s revenue agent
reviewer, with 32 years of experience in issuing notices of
deficiency, and Dwight Davies, a Postal Service employee with 28
years of experience in handling certified mail and Forms 3877.
They testified that certified mail would be returned to
respondent if it was not received by the addressee. Diana
Calverley, respondent’s revenue agent, also testified that, on a
previous occasion, petitioner had refused to accept certified
mail from respondent. That occasion related to an IRS summons
that had been issued to petitioner’s bank for matters concerning
the taxable years involved in the instant case, a copy of which
respondent had mailed to petitioner, via certified mail, return
receipt requested, at his last known address; i.e., 328 County
Road, Madison, CT 06443. Petitioner was aware that he was being
audited at the time of the summons and failed to claim the copy
mailed to him. Eventually, the copy of the summons and the
envelope containing it were returned to respondent with an
indication on the envelope that the post office had notified
petitioner three times of the attempt to deliver the item, but
that petitioner failed to claim it.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011