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The petition was received by the Court after the expiration
of the 90-day filing period, and petitioner has failed to meet
the criteria stated in the regulations to prove a timely filing.
Accordingly, we hold that this case must be dismissed for lack of
jurisdiction on the ground that the petition was not timely
filed. Petitioner could have avoided such a result if the
envelope containing the petition had been mailed by registered or
certified mail and postmarked by the U.S. Postal Service on or
before September 18, 2000. See sec. 7502(a), (c); sec. 301.7502-
1(c)(2), Proced. & Admin. Regs.
To reflect the foregoing,
An order and order of
dismissal for lack of
jurisdiction will be entered.
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Last modified: May 25, 2011