Sarah R. Elgart and Stephen K. Glassman - Page 4

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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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