RD or ND for the 6 mont rule

IP008

Registered Users (C)
For the date to start counting for the 6 month rule, which date is considered.
Is it
1. the postal date when the 485 application is sent
2. The receipt date
3. Notification date
 
No Title

In my opinion it should be ND. But one has to clarify if 180 days means 180 calendar days and not 180 working days.
 
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