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Petitioner contends that (1) on February 21, 1997, he
delivered the photocopied returns with original signatures for
the years in issue to the Baltimore District Director’s office,
and (2) his delivery of that set of returns constitutes filing of
those returns.2 Respondent contends that petitioner’s returns
for the years in issue were filed on March 10, 1997, when the
Baltimore District’s Special Procedures Office stamped them
received.
2. Whether Petitioner Delivered the Photocopied Returns
With Original Signatures for the Years in Issue to 31
Hopkins Plaza on February 21, 1997
We next decide whether, as petitioner contends, he delivered
to 31 Hopkins Plaza in Baltimore on February 21, 1997, the
photocopied returns with original signatures for the years in
issue.
The cover letter petitioner delivered on February 21, 1997,
to the office of District Counsel shows that he intended to file
his original returns with the office of District Counsel, and
intended to deliver a copy of those returns to the District
Director.
Petitioner testified that, on February 21, 1997, he
delivered an envelope containing his photocopied returns with
original signatures for 1981-95 to an individual in the office of
2 Petitioner concedes that delivery of his original returns
with original signatures to respondent’s office of District
Counsel does not constitute filing of those returns.
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