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Based on the record presented, we hold that petitioner has
failed to satisfy his burden of proof. The proof submitted by
petitioner is limited to his testimony at the hearing on August
16, 1995, and the statements contained in his Rule 50(c)
statement. Petitioner states that he distinctly remembers
placing the envelope bearing the petition in the metered mail
slot at the U. S. Post Office located at Grand Central Station in
New York City at approximately 5:15 p.m. on February 27, 1995.
Unfortunately, without more, we are unable to accept uncritically
petitioner's professed recollection of the events surrounding the
mailing of the petition. See Tokarski v. Commissioner, 87 T.C.
74, 77 (1986) (the Court is not required to accept a taxpayer's
self-serving testimony as gospel). Such professed recollection
does not, by itself, constitute convincing proof that the
envelope bearing the petition was timely deposited in the United
States mail on the critical date. Under the circumstances, we
hold that petitioner failed to prove that the envelope actually
entered the United States mail system on February 27, 1995, as
alleged.
Even if petitioner is deemed to have satisfied the timely
mailing requirement of the three-prong test of section 301.7502-
1(c)(1)(iii)(b), Proced. & Admin. Regs., there is no evidence in
the record demonstrating either that the delay in the delivery of
the envelope was due to a delay in the transmission of the mail
or the cause of any such delay. See Grassam v. Commissioner,
T.C. Memo. 1994-504. We observe that the envelope is not torn,
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