6
received this notice in or around February 1994 by regular first
class mail.
By letter dated February 23, 1994, received by the Court on
February 28, 1994, petitioners sought a redetermination of
deficiencies for the taxable years 1988, 1989, and 1991. This
Court filed the letter as a petition and ordered that a proper
amended petition be filed. Petitioners filed their amended
petition on August 2, 1994, contesting the deficiencies
determined for 1988, 1989, and 1991. They also attached the
notices of deficiency to their amended petition.
In the notice of deficiency for 1988 and 1989, respondent
determined deficiencies in petitioners' Federal income tax in the
amounts of $6,581.04 and $9,256, respectively, and an addition to
tax for 1988 under section 6651 in the amount of $1,180.75. In
the notice of deficiency for 1991, respondent determined a
deficiency in petitioners' Federal income tax of $3,274. For
purposes of this opinion, we need not address the merits of
respondent's determinations. Our only task is to decide whether
the notice for 1988 and 1989 was sent to petitioners' last known
address pursuant to section 6212(b)(1).
Assuming, arguendo, that the notice for 1988 and 1989 is
valid, the 90-day period for filing a petition with this Court
expired on September 19, 1993, which date was not a legal holiday
in the District of Columbia. The petition was not filed in this
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