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 thisPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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