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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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