On April 17, 2014, the IRS issued a notice of deficiency to the petitioner for tax years 2011 and 2012. The petitioner timely sent two separate but identical petitions to the U.S. Tax Court in dispute of the notice. One petition was sent by FedEx First Overnight and was received by the court on Jul. 17, 2014. The other petition was sent by certified mail and was mailed on Jul. 16, 2014, and received by the court on Jul. 21, 2014. While the petition mailed by certified mail satisfied the timely mailing rules of I.R.C. Sec. 7502, FedEx First Overnight is not on the IRS list of designated private delivery services providing protection under the timely mailing rules of I.R.C. Sec. 7502. The IRS filed a motion to close the case assigned a docket number based on the U.S. mailed petition on the grounds that it was duplicative of the petition mailed by FedEx. The result, had the motion been granted, would have been to dismiss the entire action for lack of jurisdiction because the FedEx petition was not timely mailed under IRS rules. The court denied the motion and instead dismissed the petition based on the FedEx filed petition. The court noted that the petitioner should be granted "the greatest protection under section 7502." Bulakites v. Comr., No. 16719-14 and 16878-14 (filed Sept. 24, 2014).