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U.S. 453, 462 (1930); Friedmann v. Commissioner, T.C. Memo. 2001-
207 (documents not treated as filed returns where nothing in the
record shows that the taxpayer intended his delivery of documents
to an agent to constitute filing of returns). A taxpayer may
not, by his or her own ambiguous conduct, even if unintentional,
secure the benefit of the limitations period. See Lucas v.
Pilliod Lumber Co., 281 U.S. 245, 249 (1930). Petitioner did not
intend the returns that he delivered to the District Director to
be his filed returns. Petitioner did not treat the photocopied
returns with original signatures enclosed in the envelope that he
gave to an unidentified employee at 31 Hopkins Plaza as returns
he intended to file. He did not indicate that the envelope
contained his tax returns, he did not request a receipt, and he
did not ask that a copy of the cover letter be date-stamped, as
he had done at District Counsel’s offices. Petitioner’s February
21, 1997, transmittal letter said he intended the original
returns with original signatures, which he delivered to
respondent’s office of District Counsel, to be his filed returns.
Thus, petitioner did not file his returns for 1987-90 or 1992-95
by hand delivering photocopies of his original returns with
original signatures to 31 Hopkins Plaza on February 21, 1997.
Petitioner’s returns were filed on March 10, 1997, when the
Baltimore Special Procedures Office of the District Director
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