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postmark. A strip showing an indecipherable barcode was affixed
to the bottom of the envelope in question.
Since around the end of 2001, the regular U.S. Postal
Service mail sent to and received by the Court has been subject
to irradiation treatment. As a result of that treatment, the
Court has experienced delays in the receipt of such mail, al-
though the delays have been relatively brief over the past
several years.3 The envelope containing the petition and the
January 16, 2007 check that the Court received does not bear any
obvious signs of irradiation treatment.
Discussion
The Court’s jurisdiction to redetermine a deficiency depends
upon the issuance of a valid notice of deficiency and a timely
filed petition. Rule 13(a), (c); Monge v. Commissioner, 93 T.C.
22, 27 (1989).
The petition in the instant case was timely filed if it was
filed within 90 days after the 2000 notice was mailed, see sec.
6213(a), or on or before January 16, 2007, see id.4 The petition
3The Court takes judicial notice of the facts concerning the
irradiation treatment of the regular U.S. Postal Service mail
sent to and received by the Court and the delays caused by such
treatment.
4On Oct. 16, 2006, respondent mailed to petitioner by
certified mail the 2000 notice. The 90-day period for timely
filing a petition with respect to that notice (not counting
Saturday, Sunday, or a legal holiday in the District of Columbia
as the last day) expired on Jan. 16, 2007. See sec. 6213(a).
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Last modified: November 10, 2007