Fred Allnutt - Page 9




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               Petitioner contends that (1) on February 21, 1997, he                    
          delivered the photocopied returns with original signatures for                
          the years in issue to the Baltimore District Director’s office,               
          and (2) his delivery of that set of returns constitutes filing of             
          those returns.2  Respondent contends that petitioner’s returns                
          for the years in issue were filed on March 10, 1997, when the                 
          Baltimore District’s Special Procedures Office stamped them                   
          received.                                                                     
               2.   Whether Petitioner Delivered the Photocopied Returns                
                    With Original Signatures for the Years in Issue to 31               
                    Hopkins Plaza on February 21, 1997                                  
               We next decide whether, as petitioner contends, he delivered             
          to 31 Hopkins Plaza in Baltimore on February 21, 1997, the                    
          photocopied returns with original signatures for the years in                 
          issue.                                                                        
               The cover letter petitioner delivered on February 21, 1997,              
          to the office of District Counsel shows that he intended to file              
          his original returns with the office of District Counsel, and                 
          intended to deliver a copy of those returns to the District                   
          Director.                                                                     
               Petitioner testified that, on February 21, 1997, he                      
          delivered an envelope containing his photocopied returns with                 
          original signatures for 1981-95 to an individual in the office of             


               2  Petitioner concedes that delivery of his original returns             
          with original signatures to respondent’s office of District                   
          Counsel does not constitute filing of those returns.                          





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