Estate of Marguerite M. Cranor, Deceased, John R. Phillips, Jr., Administrator ad Litem - Page 11

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          or organization may be reached.  See American Heritage Dictionary           
          20 (2000).  Applying the common meaning of the term “address” to            
          the facts of this case, we conclude that the “Hold Saturday” box            
          on the FedEx airbill was not part of the address of this Court.             
               Respondent relies on cases in which we held that envelopes             
          were not properly addressed which were addressed to courts other            
          than the Tax Court, to the wrong street address and wrong city,             
          or to a box number and ZIP code which had been changed.  See,               
          e.g., Estate of Cerrito v. Commissioner, 73 T.C. 896 (1980); C.             
          Frederick Brave, Inc. v. Commissioner, 65 T.C. 1001 (1976);                 
          Hoffman v. Commissioner, 63 T.C. 638 (1975); Axe v. Commissioner,           
          58 T.C. 256 (1972); Lurkins v. Commissioner, 49 T.C. 452 (1968).            
          Respondent’s reliance on these cases is misplaced because the               
          envelope containing the petition in this case was properly                  
          addressed to the Tax Court.                                                 
               The fact that Reynolds checked “FedEx Standard Overnight -             
          Next Business Afternoon” and that he did not list an address of a           
          FedEx office to hold the envelope shows that Reynolds intended              
          that FedEx promptly deliver the envelope to the Tax Court.  It is           
          true that Reynolds misunderstood the meaning of “Hold Saturday”             
          on the airbill.  However, we do not believe that his checking the           
          “Hold Saturday” box or any of the events occurring after Reynolds           
          deposited the September 3 envelope with FedEx, including his                
          prompt remailing in a new envelope of the petition to this Court            
          on September 16, 1999, prevent application of the familiar                  

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