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Although this case involves a dispute that went to the Tax Court, it would apply equally to filing returns or remitting payments to the IRS.nnThe case: N was assessed taxes by the IRS and decided to appeal by filing a petition with the Tax Court, using a third-party delivery service instead of USPS. When the package arrived at the Tax Court one day after the filing deadline, the petition was denied as late.nnHeld: For the IRS. The taxpayer had used FedEx Ground to deliver the petition. The court estimated that the voluminous petition cost about $17 to send this way—FedEx 2Day would have cost about $54.nnThe taxpayer argued that the petition should be considered timely filed under the “timely mailed, timely filed” rule. But the rule applies only when a document is filed through either USPS or a “designated private delivery service.” IRS regs list acceptable private delivery services, which includes FedEx 2Day but not FedEx Ground. Because the taxpayer chose a service not on the list, the submission would be judged by the date of arrival—not the date mailed. Had it been sent by a designated service, the package had only to be delivered to the shipping service by the deadline. The court said it had no leeway to waive the filing deadline or accept a private delivery service other than those on the IRS’s list of designated services.nn[Nguyen v. Commissioner, T.C. Memo 2023-151]...