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attorney returned to her office, reviewed and signed the
petition, and, because of the late hour, actually assisted the
assistant and the summer law clerk in making some necessary
photostatic copies to file with the petition. Her assistant and
summer law clerk put the petition signed by petitioner's attorney
in an envelope properly addressed to this Court, placed the
proper amount of metered postage on the envelope, and placed a
metered postmark of June 15, 1995, on the envelope. After this
was done, this envelope, together with other mail from the office
of petitioner's attorney that was to be sent out that date was
taken by petitioner's attorney's assistant, and he and
petitioner's attorney and petitioner's attorney's summer law
clerk all left the attorney's office together and went down to
the ground floor in the building in which the attorney's office
was located in Birmingham, Alabama. The assistant placed all of
the mail he had to mail for June 15, 1995, in a U.S. Postal
Service mailbox on the ground floor of the building.
Petitioner's attorney's summer law clerk and petitioner's
attorney saw the assistant place the mail in the mailbox sometime
between 5:30 and 6 p.m.
An envelope properly addressed to the U.S. Tax Court in
Washington, D.C., and mailed by regular mail from the Birmingham,
Alabama, area bearing a U.S. postmark with a date in June 1995
would ordinarily take 3 business days to reach the U.S. Tax
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