- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011