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have been misrepresented or falsified, casting doubt on the
authenticity of the dates on the rest. For example, petitioner
offered into evidence an undated letter from him addressed to the
Internal Revenue Service, Collection Division, Atlanta, Georgia,
in which he demands payment of refunds for the 1988 and 1989
taxable years. Attached to the letter as it was offered as an
exhibit is a U.S. Postal Service Receipt for Certified Mail, with
the addressee noted as “IRS Service Center, Atlanta Georgia” and
a postmark of January 23, 1991. The clear import of stapling the
January 23, 1991, certified mail receipt to the undated letter
was to suggest that the letter had been sent on that date.
However, petitioner also introduced the identical undated letter
into evidence in two other formats. In one, the undated letter
has attached to it a May 2, 1994, letter from respondent to which
the undated letter appears to respond. In yet another exhibit,
the copy of this same undated letter contains a stamp indicating
receipt by respondent on June 8, 1994.
In another example, respondent introduced into evidence a
letter written to respondent by petitioner which was dated
February 24, 1995, and, according to both the date filled out on
the facsimile cover sheet and the date stamp of the facsimile
machine, was faxed to respondent on February 27, 1995. This
February 1995 letter made specific reference to, and attached a
copy of, another letter which petitioner claimed he had written
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