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respondent. See United States v. Lombardo, 241 U.S. 73, 76
(1916). As previously discussed, we do not find petitioner’s
testimony, or the corroborating evidence he has offered, reliable
or credible with respect to his claim that he timely filed his
returns for the years in issue. Moreover, even if any of
petitioner’s evidence were reliable, it would still fall short of
the type of corroboration we have found sufficient to prove
timely filing when a return is lost and the Commissioner has no
record of receiving it. Typically, we have required reliable
testimony or other corroborating evidence of the circumstances
surrounding the return’s preparation and mailing. See, e.g.,
Estate of Wood v. Commissioner, 92 T.C. 793 (1989), affd. 909
F.2d 1155 (8th Cir. 1990); Mitchell Offset Plate Serv., Inc. v.
Commissioner, 53 T.C. 235, 239-240 (1969); see also Rakosi v.
Commissioner, T.C. Memo. 1993-68 (taxpayer failed to prove she
filed her return where she did not produce any documentary
evidence of timely mailing and relied solely on the self-serving
testimony of herself and her husband), affd. without published
opinion 46 F.3d 1144 (9th Cir. 1995). Here petitioner has
offered no corroborating evidence with respect to the
preparation, mailing, or delivery of the returns. Thus we
conclude that petitioner did not file his 1988 and 1989 returns
prior to October 4, 1993. Since we conclude that petitioner did
not submit returns for the years in issue until October 4, 1993,
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