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Q What does that mean?
A Normally, that is the date the return is received,
but in this case, I cannot tell you why the Service Center put
that date in there. I can only speculate.
Q But in general, that would be the date that they--
they claim they received a filed return?
A In general, that’s correct.
Q Okay. And that’s in there for all three years?
A That’s correct.
Q 16-, 17- and 18-J?
A That’s correct. It’s the same date on all three
years.
Respondent’s counsel produced the transcripts of account, and
called Hartz as a witness, to show that respondent’s records do not
show that petitioner filed a tax return for 1993, 1994, or 1995
before December 4, 1998. However, as the foregoing makes plain,
each of the transcripts of account appears to show that respondent
received petitioner’s tax return for each year as of March 11,
1997. Respondent’s counsel did not have a witness who could
explain this inconsistency that was apparent on the face of each
transcript of account.
We had already concluded that it is more likely than not that
petitioner and Evalyn filed a tax return for each year before
December 4, 1998. See Popa v. Commissioner, 73 T.C. 130, 133, 135
(concurring opinion) (1979). In light of the evidence on
respondent’s transcripts of account, together with the testimony of
respondent’s chosen witness, we conclude, and we have found, that
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