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The petition was signed by petitioner’s attorney, Marc C.
Rosenberg (Mr. Rosenberg), on September 11, 2000. The petition
was received and filed with this Court on September 28, 2000.
The envelope in which the petition arrived at the Court bears a
private postage-meter postmark that reads, in part, “Tarzana CA
Sep.15.00 POSTALIA 288967".2
At the hearing on respondent’s motion, Mr. Rosenberg
testified that on Friday, September 15, 2000, he applied the
postage on the envelope addressed to the Tax Court. Mr.
Rosenberg stated that he then dropped the petition into the
office building’s mail receptacle “in the evening” at the end of
the day, apparently after the last U.S. Postal Service pickup at
4 p.m. It is unclear whether the U.S. Postal Service picked up
the mail from his office building on Saturday, the following day.
There is no Sunday pickup.
Mr. Rosenberg used a Francotyp-Postalia, model T-1000 (T-
1000), postage meter to apply the postage and date on the
envelope addressed to this Court. Although the T-1000
automatically sets the date and time for postal metering, the
operators manual provides simple step-by-step instructions under
the heading “To Change the Date Manually” to override its
automatic internal clock. The T-1000 does not have any internal
2
POSTALIA refers to a private postage meter,
specifically known as Francotyp-Postalia, model T-1000.
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Last modified: May 25, 2011