Charles Crellin Douglass - Page 2

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          tion over either 1991 or 1995.                                              
                                     Background                                       
               Petitioner resided in Houston, Texas, at the time he filed             
          the petition in this case on December 9, 1996.  In that petition,           
          petitioner disputed a deficiency, an addition to tax under                  
          section1 6651(a)(1), and a penalty under section 6662 that were             
          determined by respondent in a notice of deficiency issued to him            
          for 1991 (1991 notice).  He also disputed a deficiency and a                
          penalty that he alleged were determined in a notice of deficiency           
          issued to him for 1995.                                                     
               The record in this case establishes, and the parties con-              
          cede, the following facts:                                                  
               On December 15, 1994, petitioner filed for bankruptcy                  
          (petitioner's bankruptcy case) in the U.S. Bankruptcy Court for             
          the Southern District of Texas, Houston Division (Bankruptcy                
          Court).  On October 19, 1995, respondent mailed to petitioner the           
          1991 notice.  That notice stated in pertinent part:                         
                    Even though you are in bankruptcy, you may want to                
               contest this deficiency in the United States Tax Court.                
               Under Bankruptcy Code section 362(a)(8), however, the                  
               filing of a petition with the Tax Court is automati-                   
               cally stayed because of your bankruptcy case.  When the                
               automatic stay is in effect, you must ask the Bank-                    
               ruptcy Court (under Bankruptcy Code section 362(d)(1))                 
               to lift the stay so you can file a petition with the                   
               Tax Court.  You have 90 days from the date of this                     
               letter (150 days if the letter is addressed to you                     
               outside the United States), plus any additional period                 

          1  All section references are to the Internal Revenue Code in               
          effect at relevant times.                                                   




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