While I am a lawyer, and have argued such technicalities in my own practice, I'm also removed enough from the process as a citizen to find it disturbing that issues like whether a Wal-Mart store does or does not get located in a particular community (one decision has gone each way so far on this basis) get decided based on whether someone
sent a letter by certified mail rather than first class mail, when there is no dispute that the letter was received by the right person at the right time. Matters of importance shouldn't be decided based on technicalities in those common situations when the technicalities involved turn out to be harmless errors.
This issue of proper mailing is less of a harmless technicality in the cases address here because in cases involving late filed tax papers, the papers are generally actually delayed for some reason.
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