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contradict respondent’s evidence that a final notice of
determination was mailed to petitioner on October 23, 2004.
Moreover, the claims made by petitioner are refuted by USPS
published policies. The USPS maintains certified mail records
for a period of 2 years before they are purged from the USPS
system.11 See http://www.usps.com. Petitioner asserts that he
checked the certified mail number through the USPS online track
and confirm system and that he spoke by telephone with a USPS
representative on December 27, 2006. If the final notice were
mailed, as respondent asserts, on October 23, 2004, more than 2
years before petitioner’s inquiries, any record of the final
notice’s certified mail number would have already been purged
from the USPS system.
Respondent has offered evidence showing that respondent
mailed the final notice to petitioner on October 23, 2004.
Petitioner has offered no evidence to contradict that evidence.
Petitioner was required to respond to the final notice by
requesting a section 6330 hearing within the 30-day period
permitted by section 6330(a)(3)(B). Respondent sent petitioner
the final notice on October 23, 2004. Petitioner’s section 6330
hearing request needed to be postmarked by November 22, 2004, to
be timely mailed; petitioner did not mail his request until April
11 Delivery information for certified mail is accessible on
the USPS Web site for 60 days, after which the information is
archived and moved to offline storage. See http://www.usps.com.
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Last modified: November 10, 2007