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functions indicating whether the time or date had been altered
from its original setting.
Respondent’s witness, William Pace (Mr. Pace) from the U.S.
Postal Service, testified that ordinary delivery of first class
mail from Tarzana, California, to Washington, D.C., is about 3
days. Furthermore, about 89.7 percent of first class mail sent
from Tarzana, California, to Washington, D.C., is delivered
within 3 days. The percentage increases to about 97 to 98
percent of such mail being delivered within 4 days, and nearly
100 percent delivered within 5 days. Mr. Pace’s testimony is
based on monthly statistics maintained by the U.S. Postal
Service. According to the records maintained by the
Transportation and Network Division of the Santa Clarita
Processing and Distribution Center of the Postal Service, no
special circumstances existed during the period of September 15
through 28, 2000, that would explain the delay in delivery of the
petition.
Discussion
This Court’s jurisdiction to redetermine a deficiency
depends upon the issuance of a valid notice of deficiency and a
timely filed petition. See Rule 13(a), (c); Monge v.
Commissioner, 93 T.C. 22, 27 (1989); Normac, Inc. v.
Commissioner, 90 T.C. 142, 147 (1988).
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