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has spoken with Mr. Gregory S. Hrebiniak, Department of
Justice, who instructed him to have me file said
returns with District Counsel.
Petitioner delivered the original returns with original
signatures for 1981-95, accompanied by the letter of transmittal,
to Henn’s secretary at the Baltimore, Maryland, Office of
District Counsel, 200 St. Paul Place, Suite 2602, at about 11:25
a.m. on February 21, 1997. At that time, petitioner intended
those to be his filed returns, and he believed that he had filed
those returns by delivering them to the office of District
Counsel. Henn’s secretary date stamped and signed a copy of the
transmittal letter.
Petitioner then went to respondent’s offices at 31 Hopkins
Plaza, Baltimore, which included the office of the Baltimore
District Director. Petitioner entered the building at about
11:45 a.m. and asked a security guard for directions to
Harrington’s office. The guard told petitioner that Harrington
was at lunch and directed petitioner to a second person.
Petitioner asked that person for directions to Harrington’s
office. That second person told petitioner that Harrington was
at lunch and that he (the second person) could hold the package
and give it to Harrington when Harrington returned from lunch.
Petitioner asked the second person if he had authority to accept
documents on Harrington’s behalf, and the second person said that
he did. Petitioner wrote “Attn: Paul Harrington” on the
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