- 2 - pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The motion was calendared for hearing and was heard. Respondent determined against petitioners the following deficiencies in Federal income taxes, additions to tax, and penalties for the years indicated: Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1993 $7,977 $1,995 $ 963 1994 5,251 263 1,050 At the time the petition was filed, petitioners' legal residence was Tulsa, Oklahoma. Respondent mailed the notice of deficiency by certified mail, on June 14, 1996, to petitioners' last known address. The period for timely filing the petition in this Court, pursuant to section 6213(a), ended Thursday, September 12, 1996, which date was not a legal holiday in the District of Columbia. The petition was filed with this Court on October 16, 1996, which date was 124 days after the mailing of the notice of deficiency. Respondent contends the petition was not timely filed within the time prescribed by sections 6213(a) and 7502(b) and the 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011