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In addition to the foregoing difficulties with petitioner’s
corroborating evidence, his own testimony is highly implausible.
As an explanation for the absence of stamped copies of the
purportedly hand-delivered and timely filed returns, petitioner
claims that he inadvertently discarded them in May 1993 when he
disposed of records relating to his divorce proceedings. We find
it implausible that petitioner would not have kept closer track
of these returns if, as he claims, he had experienced trouble in
the past with the IRS losing his returns. Moreover, petitioner
claims to have written, and has introduced into evidence, several
letters inquiring about his refunds for 1988 and 1989 which
purportedly were written prior to May 1993. We find it
remarkable, given petitioner’s work experience with the IRS, that
not one of these letters expressing concern about overdue refunds
enclosed a copy of the timely filed returns for the years in
issue if such returns were in fact in petitioner’s possession
until May 1993. Finally, we find it implausible that petitioner
discarded the returns, yet managed to retain copies of extensive
pre-May 1993 correspondence that he purportedly sent to
respondent concerning the returns.
The parties agree that petitioner submitted returns for 1988
and 1989 on October 4, 1993. Petitioner contends that such
returns were merely duplicates of previously filed, timely
returns. Respondent contends that no returns for 1988 or 1989
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