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This case is before the Court on respondent's Motion to
Dismiss for Lack of Jurisdiction, filed pursuant to Rule 53. The
issue that we must decide is whether petitioners filed their
petition with the Court within the time period prescribed by
section 6213(a).
Background
At the time that the petition was filed with the Court,
petitioners' mailing address was 1596 Shallowwell Road, Manakin
Sabot, Virginia 23103-2312 (the Manakin Sabot address).
On January 16, 1996, respondent mailed a notice of
deficiency to petitioners. In the notice, respondent determined
a deficiency in petitioners' Federal income tax for the taxable
year 1993 in the amount of $11,622, as well as an accuracy-
related penalty under section 6662(a) in the amount of $2,324.
The notice of deficiency was mailed to petitioners by registered
mail at the Manakin Sasbot address.
On May 1, 1996, a petition was filed with this Court seeking
a redetermination of a portion of the deficiency determined by
respondent for the taxable year 1993.2 The petition was executed
by Arlene Berliner (Ms. Berliner), an individual associated with
2 The petition disputes only $9,526 of the $11,622
deficiency determined by respondent. Further, the petition does
not contest or otherwise place in dispute any portion of the
accuracy-related penalty. See Rule 34(b)(4) ("Any issue not
raised in the assignment of errors shall be deemed to be
conceded.").
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