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petition with this Court. Ms. Steinhauer was advised that the
final due date for filing a petition with this Court was March
14, 1996. Ms. Steinhauer sent a letter confirming this
information to Ms. Lowden at the IRS on December 18, 1995.
On January 25, 1996, petitioner Stephen K. Glassman and Ms.
Steinhauer attended a meeting with Revenue Agent Kim Slater.
During that meeting they were advised by Ms. Slater that a
petition with this Court could be filed and was due by March 14,
1996.
Petitioners filed a petition for redetermination with this
Court on March 18, 1996. The petition was delivered to the Court
by certified mail in an envelope bearing a U.S. postmark date of
March 14, 1996. The 90-day period for filing a petition with
this Court expired on Wednesday, March 13, 1996, which date was
not a legal holiday in the District of Columbia.
As indicated, respondent filed a Motion to Dismiss for Lack
of Jurisdiction on the ground that the petition was not filed
within the 90-day period prescribed in section 6213(a). On June
3, 1996, petitioners filed an objection to respondent's motion to
dismiss, alleging that respondent failed to mail the original
deficiency notice by registered or certified mail to their last
known address, which they contend is the address of their
authorized representative Ms. Steinhauer, and, as a result, the
90-day period to file a petition did not begin to run until the
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