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Petitioners have not argued or presented evidence that there
was a delay in delivery attributable to delay in the transmission
of the mail, and the cause of the delay. Consequently,
petitioners have failed to establish that they qualify for the
timely mailing/timely filing rule of section 7502. Accordingly,
we hold that the petition was not timely filed.
An appropriate order of
dismissal for lack of
jurisdiction will be entered.
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Last modified: May 25, 2011