Judge Adam B. (“Sport”) Landy gives that directive to Tarek Koussayer & Azza Husseini, Docket No. 1611-23, filed 4/21/25. This is a many-times-told tale, but it needs to be told periodically.

The envelope wherein the petition was mailed in this deficiency case had a Pitney-Bowes meter mark within the 90-day cutoff, but a USPS postmark two (count ’em, two) days late.

“Petitioners maintain that this Court should consider the extrinsic evidence contained in their Response to the Order to Show Cause in determining that the Petition was timely filed. Although extrinsic evidence is allowed to prove the date of mailing where an envelope containing a Tax Court petition lacks a postmark or the postmark is illegible, such evidence is irrelevant where the envelope bears a legible USPS postmark dated after the 90th day prescribed for filing a timely petition.” Order, at p. 2. (Citations omitted).

Even with the USPS postmark date, the petition didn’t get logged in to The Glasshouse in the City of Efficient Government for more than a month later.

Procrastination in the face of unalterable deadlines is never a good policy.