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In 1992, during the audit of petitioner's 1988 income
tax return, respondent's revenue agent requested copies of
petitioner's 1989 and 1990 returns. In April 1992,
petitioner gave photocopies of those returns to the agent.
At that time, the agent believed that petitioner had
previously filed the returns with the Internal Revenue
Service. Petitioner gave the agent no indication
otherwise. Both returns had been signed before they were
photocopied, and neither return bore petitioner's original
signature. In September or October 1992, the agent began
an examination of petitioner's 1989 and 1990 returns.
In due course, the revenue agent found that the
Internal Revenue Service had no record of having received
either the 1989 or 1990 return. The agent notified
petitioner, by letter dated November 6, 1992, that the
photocopied returns would be processed as delinquent
returns once the agent received a copy of each return that
bore petitioner's original signature. The agent's letter
states as follows:
As per our telephone conversation yesterday,
I will process the previously submitted copies
of your 1989 & 1990 1040 income tax returns as
delinquent returns since our records do not
indicate receipt of the aforementioned at the
service centers. However, before I can process
the copies I need them to have original signa-
tures. Please provide same above the copied
signature (also date) and return them to me so
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