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The notice of determination informed petitioner that if he
wanted to dispute respondent’s determination in court, then he
must file a petition with this Court “within 30 days from the
date of this letter.”
On November 13, 2002, petitioner purchased a U.S. Postal
Service Postal Money Order in the amount of $60. The Postal
Money Order was payable to “United States Tax Court” and was
purchased to pay the filing fee for commencing a lien or levy
action in this Court. See Rule 331(c). Petitioner listed his
address on the Postal Money Order as the P.O. box address.
On Friday, November 29, 2002, the Court received and filed a
Petition for Lien or Levy Action Under Code Section 6320(c) or
6330(d). The petition, which is undated, arrived at the Court in
a properly addressed envelope that identifies the P.O. box
address as the return address.2 Significantly, the envelope,
which was mailed to the Court by U.S. Postal Service Express
Mail, bears a legible postmark date of Wednesday, November 27,
2002.3
Shortly after this case was calendared for trial, respondent
moved to dismiss the petition for lack of jurisdiction on the
2 In contrast, petitioner used his street address on the
petition itself.
3 We note that Thursday, Nov. 28, 2002, was Thanksgiving
Day, a legal holiday in the District of Columbia, see Rule
25(b), and that there was no mail delivery to the Court on that
day.
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