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Petitioners have already paid the addition to tax under section
6653(a)(1) in the amount of $15.60.2
On April 7, 1995, respondent issued an additional notice of
deficiency for the 1982 taxable year (the second notice of
deficiency) to petitioners at the same address, determining the
following additions to tax with respect to the tax adjustments
related to Whitman:
Additions to Tax
Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659
1982 $853 50 percent of $4,620
the interest due
on $17,068
This Court’s jurisdiction is strictly limited by statute,
and, unless a petition is filed within the time prescribed by
statute, we lack jurisdiction and must dismiss the case for that
reason. Estate of Moffat v. Commissioner, 46 T.C. 499, 501
(1966). A petition must be filed within 90 days after the notice
of deficiency is mailed to a taxpayer within the United States.
Sec. 6213(a). If the notice is addressed to a person outside the
United States, the taxpayer receives 150 days to file a petition.
Id.
The 90-day period for filing a petition with this Court
expired on June 14, 1995, for the first notice of deficiency and
2Prepayment by the taxpayer does not deprive the Tax Court
of jurisdiction, where payment is made after the mailing of the
notice of deficiency. Sec. 6213(b)(4).
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Last modified: May 25, 2011