Moshe Rothbard - Page 2




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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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