MEMORANDUM OF OPINION AND ORDER
LEVI, District Judge.
This case presents the curious question of what proof of timely postmark may be offered by a taxpayer when the Internal Revenue Service (IRS) receives a filing several days after the due date, by first class mail, and does not keep the envelope. According to the IRS, the only proof admissible is "direct" evidence of a timely postmark as opposed to proof of timely mailing from which a timely postmark...
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