It’s such a cliché, but this is one on which I am prepared to wager an ale or two at Jake’s Saloon that you can’t make this stuff up. But let Judge Nega tell the story of Rosie K. Boparai, Docket No. 7789-25, filed 6/30/26.

“Petitioner’s tax return for 2019 was due (after the granting of an extension) on October 15, 2020. Petitioner did not file her 2019 return by that date. 

“On July 17, 2023, petitioner appeared in person at the Sacramento Taxpayer Assistance Center and attempted to hand-deliver her 2019 tax return. Respondent’s employees refused to accept her hand-delivered return without petitioner having first made an appointment for that purpose. That same day, petitioner sent an envelope containing her 2019 return that requested a refund and a check for $10,000 by certified mail to a no-longer-operated Internal Revenue Service (IRS) P.O. Box in San Francisco, California. She included the check despite claiming a refund on the return because she believed that the inclusion of a check would speed up the processing of the return.” Order, at p. 1.

Of course Section 7502 doesn’t help, because the mailpiece was misaddressed.  See Section 7502(a)(2)(B); see also Reg Section 301.7502-1(c)(1)(i). Had Rosie filed properly in 2023, she would have gotten the refund (IRS conceded the deficiency). The 2019 1040 instructions said for overdue returns, use the latest address, and the SF PO Box wasn’t it. 

“Had she consulted the instructions for tax year 2019 with the degree of detail that she claims, she would have seen the directive instructing her to refer to the tax year 2022 instructions to find the proper address for mailing her return.” Order, at pp. 3-4.

PS- IRS finally got Rosie’s return last May.