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ter, England.
On September 26, 2000, respondent mailed to petitioner at
111 Clymer St., Apt. 3E, Brooklyn, N.Y., a notice of deficiency
with respect to his taxable year 1997 (notice). The petition was
filed on January 8, 2001, 104 days after the date on which
respondent mailed the notice to petitioner.
The petition was mailed to the Court in an envelope (enve-
lope in question) that was properly addressed to the Court and
that contained a privately metered postage stamp (private postage
stamp). The private postage stamp bore the date of December 26,
2000, and showed the point of origin as Brooklyn, N.Y.
If the envelope in question had been postmarked by the U.S.
Postal Service (Postal Service) on December 26, 2000, at the same
point of origin, that envelope would ordinarily have been re-
ceived by the Court two days after the date on which it was
mailed (i.e., two days after the Postal Service postmark date of
December 26, 2000). If the envelope in question had been post-
marked by the Postal Service on December 26, 2000, at the same
point of origin, it would have been out of the ordinary for that
envelope to have been received by the Court 13 days after the
date on which it was mailed (i.e., 13 days after the Postal
Service postmark date of December 26, 2000).
While there generally is an increase in the number of pieces
of mail handled by the Postal Service during the Christmas
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Last modified: May 25, 2011