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As mentioned above, the instant petition was received
by the Court on May 20, 1996, 13 days after petitioner
alleges that it was mailed. The parties agree that the
ordinary delivery time for a properly addressed envelope
sent from Austin, Texas, to Washington, D.C., is 3 days.
Accordingly, the petition was not received by the Court
within the ordinary delivery time for mail sent from
Austin, Texas, to Washington, D.C. Therefore, under
section 301.7502-1(c)(1)(iii)(b), Proced. & Admin. Regs.,
quoted above, the petition will not be deemed filed on the
postmark date, May 7, 1996, unless petitioner establishes:
(1) That the petition was actually deposited in the mail
before the last collection of the mail on May 8, 1996,
the last day for filing the petition; (2) that the delay
in receiving the petition was due to a delay in the trans-
mission of the mail; and (3) the cause of the delay. Sec.
301.7502-1(c)(1)(iii)(b), Proced. & Admin. Regs.; see
Gomez v. Commissioner, T.C. Memo. 1996-561; Little v.
Commissioner, T.C. Memo. 1995-491.
We find that petitioner has failed to satisfy each
of the three conditions of section 301.7502-1(c)(1)(iii)
(b), Proced. & Admin. Regs. Petitioner has introduced no
evidence to show that the delay in receiving the petition
was due to a delay in the transmission of the mail, the
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