DAVID A. NELSON, Circuit Judge.
This is a tax case that presents an issue on which the circuits are divided: whether the common law "mailbox rule," under which proof of the mailing of a properly addressed communication bearing proper postage raises a rebuttable presumption of receipt in due course by the addressee, is a rule that applies to matter sent to the Internal Revenue Service by regular mail. Circuit precedent requires us to hold that the common law rule has...
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