A taxpayer has ninety days after the mailing of a notice of deficiency to file a petition for review of the deficiency in Tax Court. The petitioners delivered their petition to Federal Express on the ninetieth day. Before the Tax Court, they argued that the petition was timely under 26 U.S.C. § 7502, which provides that timely mailing of a document through the U.S. mails is the equivalent to a timely...
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