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Petitioner resided in Baltimore, Maryland, at the time the
petition was filed.
On October 16, 2006, respondent mailed to petitioner by
certified mail to his last known address, which is also his
address of record in this case, a notice of deficiency with
respect to his taxable year 2000 (2000 notice).
On January 22, 2007, the Court received a petition with
respect to the 2000 notice.1 Barry L. Dahne (Mr. Dahne), peti-
tioner’s counsel of record in this case, signed the petition.
Included in the envelope in which the petition was mailed to the
Court was a check for $60 drawn on the account of Barry L. Dahne
that was signed by him, made payable to “US TAX COURT”, and dated
“1/16/2007” (January 16, 2007 check). The Court used that check
to pay the $60 filing fee required by Rule 20(b),2 and on January
22, 2007, at 11:35 a.m., issued a receipt for that payment that
it sent to Mr. Dahne.
The envelope containing the petition and Mr. Dahne’s January
16, 2007 check that the Court received bore four first-class
stamps that were not canceled. That envelope did not bear a U.S.
Postal Service postmark. Nor did it bear a privately metered
1The Court filed the petition at 10:56 a.m. on Jan. 22,
2007.
2All Rule references are to the Tax Court Rules of Practice
and Procedure. All section references are to the Internal
Revenue Code in effect at all relevant times.
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Last modified: November 10, 2007