Tax Court Petition Not Timely Filed.

The petitioner sought a redetermination from the Tax Court and the petition was delivered to the court on the 98th day - 8 days beyond the 90-day deadline.  Normally, the petition is considered to have been filed at the time of mailing.  The petition's envelope included a "postmark" by Stamps.com on the 90th day.  However, the envelope also had a certified mail label with a tracking number and tracking data of the U.S. Postal Service showed that the USPS received the envelope on the 92nd day.  The court ignored the Stamps.com "postmark" and held that the petition had not been timely filed.  Tilden v. Comr., T.C. Memo. 2015-188