Janine Midori Fujioka and David Miura - Page 6

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               the envelope was mailed in accordance with this                         
               subdivision shall be determined solely by applying the                  
               rule of (a) of this subdivision [requiring that the                     
               U.S. Post Office postmark show mailing within the                       
               prescribed period for filing the petition].                             
          In this case, the envelope in which the petition was filed with              
          this Court bears a stamp indicating that the envelope was mailed             
          from Chicago, Illinois, on December 30, 1998.  That date is 341              
          days after the mailing of the notice of deficiency.                          
               Accordingly, we must dismiss this case for lack of                      

                                              An appropriate order                     
                                        dismissing this case for lack                  
                                        of jurisdiction will be entered.               

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