There is clear and convincing evidence in the record that petitioner tendered the subject delinquent tax payments, totaling less than $5,000, by certified check at least twice: once by Federal Express delivery received by the City Collector on August 26, 1988 and then, after the first check was misplaced or lost, by hand delivery on February 23, 1989, neither of which payments was properly credited by the City. It is also undisputed that, in response to the letter of petitioner...
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