- 4 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011