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2. Processing of the Returns Delivered to District Counsel
Respondent’s District Counsel’s office did not place any
identifying marks or stamps on the returns for the years in issue
that petitioner delivered to Henn’s secretary on February 21,
1997 (i.e., the original returns with original signatures).
Those returns were forwarded to the Baltimore Special Procedures
Office of the District Director, which stamped them received on
March 10, 1997. Someone wrote on the top of the first page of
each of those returns “Copy of Return Secured [or Received] by
Examination. 5/1/97”.
3. Processing of the Returns Delivered to 31 Hopkins Plaza
Respondent did not place a date received stamp on or make
any other record showing when respondent received the photocopied
returns with original signatures for the years in issue.
An unidentified person (or persons) in respondent’s
Philadelphia Service Center stamped the following on the front
page of each photocopied return with original signature for the
years in issue: (1) “IRS Received from District 052197”; (2)
“Postmark 050997” and “Received 051497; and (3) “Delinquent
Original Cleared for Processing by 285” on June 16, 1997, and
“Resort Received” on June 27, 1997. Someone from an unidentified
IRS office stamped on the bottom left corner of the front page of
each photocopied return with original signature for the years in
issue “POS sorted for statute review, 5-14-97”. However, that
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Last modified: May 25, 2011