Peter Pettong and Chung-Yin Chiang - Page 6

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          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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