Randall Mark Jacobson - Page 1

                                 T.C. Memo. 2000-154                                  

                               UNITED STATES TAX COURT                                

                         RANDALL MARK JACOBSON, Petitioner v.                         
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                     

               Docket No. 19890-97.                        Filed May 5, 2000.         

                    P prepared Forms 1040 as joint tax returns for 1993,              
               1994, and 1995.  P made substantial payment of estimated tax           
               for each of these years; each year’s Form 1040 directed that           
               the overpayment shown thereon be applied to the next year’s            
               estimated tax.  Respondent determined that P had not filed tax         
               returns and sent a notice of deficiency to P for each of these         
               years.  The parties have agreed that P’s tax liability for             
               each of these years is slightly more than the liability shown          
               on the Form 1040.  P contends that each tax return was filed           
               on or about Oct. 15, the extended due date of the tax return.          
               R contends that P filed tax returns for all 3 years on Dec. 4,         
               1998, and not before.                                                  
                    1.   Held:  On the basis of the record herein, P has              
               carried his burden of proving that it is more likely than not          
               that he filed joint tax returns for 1993, 1994, and 1995 on or         
               before Mar. 11, 1997, the date which is shown as the return            
               received date on the transcript of account for each of the 3           

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