Michael Stein - Page 14

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               On August 27, 2001, petitioner timely mailed his petition              
          with the Court in response to the July 26, 2001, notice of                  
          determination; the Court received and filed the petition on                 
          September 4, 2001.7                                                         
          Discussion                                                                  
               As a preliminary matter, we note that petitioner’s mail and            
          living arrangements, which have created and continue to create              
          difficulties in contacting him, and his repeated failures to                
          comply with deadlines, have impeded and delayed respondent’s                
          collection efforts and the efforts of the Court to resolve these            
          matters.                                                                    
               We note that petitioner has uttered contradictory testimony            
          and arguments and has failed to provide respondent and the Court            
          with reliable information and documents to resolve this matter.             
          Petitioner bears the risk of loss and the responsibility arising            
          from failure to prepare and file returns and to preserve and                
          locate his cost records and copies of prior returns for use in              
          substantiating items required to be reported on his returns for             
          the years in issue.                                                         



               7Petitioner’s mailing of the petition was a timely filing on           
          the last day of the 30-day period specified by secs. 6320(c) and            
          6330(d), as extended by Rule 25.  Aug. 25 and 26, 2001, were a              
          Saturday and Sunday, respectively, and petitioner mailed the                
          petition on Monday, Aug. 27, 2001.  See Guerrier v. Commissioner,           
          T.C. Memo. 2002-3.                                                          





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