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section 6654(a) are based on respondent's determination that
petitioner failed to pay the requisite estimated income taxes for
the years in issue.
There is no dispute regarding the date on which the notices
of deficiency were mailed to petitioner. There is also no
dispute regarding the fact that the notices of deficiency were
mailed to petitioner at his last known address.
Petitioner filed a petition for redetermination with this
Court on March 9, 1995, which date is 99 days after the mailing
of the notices of deficiency. The petition, which was signed by
petitioner and dated February 26, 1995, was mailed to the Court
in a properly addressed envelope bearing a private postage meter
postmark date of Monday, February 27, 1995.2 The envelope, which
was approximately 9-1/2 x 12-1/2 inches in size, does not reflect
either the sender's return address or any designation by the
sender of the class of mail service desired.
The envelope in question is not torn, damaged, or unusually
soiled, nor does it appear to have been abused. There are no
Postal Service markings, stamps, or imprints appearing on the
envelope, such as a postage due stamp or an imprint indicating
the class of mail assigned to the envelope. The only marking on
the envelope is the docket number of this case, which was placed
on the envelope by Court personnel.
2 The private postage meter label affixed to the envelope
reflects postage of $3. The envelope contained petitioner's 11
page petition with exhibits and his delinquent income tax returns
for the 5 years in issue. Petitioner testified that the envelope
weighed approximately a pound.
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