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of registered mail No. R773-219-004. On June 8, 1998, the clerk
of the Court executed the Postal Service Form 1000 and
acknowledged receipt of the item of registered mail No. R773-219-
004 by checking the "Yes" box under entry No. 13a, which states:
"Did you receive items listed above?". The Court retained a copy
of the Postal Service Form 1000 in the correspondence folder in
docket No. 1418-98S.
On June 9, 1998, petitioners submitted an "Affidavit" to the
Court, which the Court filed as a petition for redetermination,
assigned docket No. 10605-98, contesting the notice of deficiency
for the years 1994, 1995, and 1996. The petition arrived at the
Court in an envelope bearing a U.S. Postal Service postmark date
of June 8, 1998. The petition includes allegations that on
February 20, 1998, petitioners' employee, Rosemary Vela, mailed a
petition to the Court in an envelope bearing registered mail No.
R773-219-004 contesting the notice of deficiency for 1994, 1995,
and 1996. The affidavit further states that, on June 1, 1998,
petitioners were informed by the Tax Court's "90-day clerk" that
the Court had not received the petition, prompting petitioners to
initiate a "tracer" on registered mail No. R773-219-004.3 At the
time that the petition was filed, petitioners resided in Corpus
Christi, Texas.
3 The Tax Court does not have any personnel positions with
the title "90-day clerk". We surmise that petitioners may have
spoken with someone in respondent's office.
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