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to respondent in 1993. However, the attached copy of the letter
claimed by petitioner to have been written in 1993 is dated
August 27, 1995. Asked at trial to account for this
chronological discrepancy, petitioner offered no explanation.
We conclude that petitioner is, at best, confused about when
he sent written correspondence to respondent. On this record, we
find that the dates on the letters petitioner claims to have sent
to respondent are unreliable, because it has been demonstrated in
at least two instances that petitioner’s claims about the dates
of his letters are in error, creating an inference that the dates
on other correspondence introduced by petitioner may have been
altered. Moreover, there is insufficient evidence that the
letters relied on by petitioner were in fact mailed to
respondent. The one certified mail receipt introduced by
petitioner is attached to a letter that other evidence indicates
was sent approximately 3-1/2 years later, as discussed supra.
Besides petitioner’s self-serving testimony, the only proof that
letters were actually mailed concerns two letters received by
respondent on June 8, 1994, and February 27, 1995. Therefore, we
conclude that the letters in the record are not probative on the
question of whether petitioner timely filed his returns or made
timely claims for refund with respect to any of the years in
issue.
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