Estate of Marguerite M. Cranor, Deceased, John R. Phillips, Jr., Administrator ad Litem - Page 10

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          has been timely mailed, a fact which is not in dispute in the               
          instant case.                                                               
               2.   Whether the September 3 Envelope Was Properly Addressed           
               Respondent contends that the envelope containing the                   
          petition was not properly addressed within the meaning of section           
          7502(a)(2)(B) because the September 3 airbill was marked “Hold              
          Saturday”.  Respondent points out that language on the back of              
          the recipient’s copy of the September 3 airbill states that the             
          sender is responsible for correctly preparing the airbill.                  
          Respondent also contends that Reynolds’ failure to correctly                
          complete the airbill caused the petition to be filed late.                  
               The FedEx airbill attached to the September 3 envelope                 
          containing the petition bore the correct name, address, and ZIP             
          code of the Tax Court.  Reynolds paid the applicable FedEx                  
          charges, and he deposited the envelope with FedEx on September 3,           
          1999, 4 days before the last day for doing so.  He incorrectly              
          checked the “Hold Saturday” box, but the “Hold Saturday” box was            
          not part of the address of this Court.  An address for purposes             
          of section 7502(a)(2)(B) is the location to which the petition is           
          to be delivered.  It is well established that we give a statutory           
          term its common and ordinary meaning unless persuasive evidence             
          or context indicates otherwise.  See Commissioner v. Soliman, 506           
          U.S. 168, 174 (1993); Commissioner v. Brown, 380 U.S. 563, 570-             
          572 (1965).  The term “address” has been generally defined to               
          mean the designation of the place or location at which a person             

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