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designating Corpus Christi, Texas, as the place of trial; and (3)
a check in the amount of $60. The envelope in question bore a
U.S. Postal Service postmark date of February 20, 1998, and
registered mail No. R773-219-004.
By letter dated February 26, 1998, the deputy clerk of the
Court (the deputy clerk) returned the above-described amended
petition to petitioners and informed them that the amended
petition had not been filed because it was incomplete. The
deputy clerk further informed petitioners that the Court does not
conduct trial sessions in Corpus Christi, Texas, and that
petitioners would have to select an alternative trial site from
the list that was enclosed with the letter. Finally, the deputy
clerk informed petitioners that their $60 check had been applied
to docket No. 1418-98 in satisfaction of the filing fee.
On March 25, 1998, petitioners filed a proper amended
petition in docket No. 1418-98 and a designation of place of
trial designating San Antonio, Texas, as the place of trial.2 In
addition, petitioners elected to have their case tried pursuant
to the small tax procedures under section 7463. Accordingly, the
docket number for the case was changed to docket No. 1418-98S.
In early June 1998, petitioners filed Postal Service Form
1000 (Domestic Claim or Registered Mail Inquiry) with the U.S.
Postal Service for the purported purpose of tracing the delivery
2 Markings on the amended petition filed Mar. 25, 1998,
reveal that the document is the same form amended petition that
the deputy clerk returned to petitioners by letter dated Feb. 26,
1998.
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