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6213(a). Unless stated otherwise, all section references
are to the Internal Revenue Code.
Background
Petitioner is a corporation. At the time the instant
petition was filed, petitioner's principal place of
business was in Austin, Texas.
Respondent issued a notice of deficiency determining a
deficiency of $19,131 in petitioner's 1992 income tax, and
an accuracy-related penalty pursuant to section 6662(a) of
$3,826.
Respondent sent the notice of deficiency by certified
mail to petitioner's last known address on February 8,
1996. The 90-day period under section 6213(a) for timely
filing a petition for redetermination in this Court expired
on May 8, 1996.
After the notice of deficiency was mailed to
petitioner, its president, Mr. Mark J. Hanna, conferred
with its attorney, Charles F. Daily, Jr., about filing a
petition for redetermination with this Court and about the
substance of the petition. Mr. Hanna was aware that the
deadline for filing such a petition was May 8, 1996, and
he met with Mr. Daily on May 7, 1996, to finalize the
preparation of a petition for redetermination.
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