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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.
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Last modified: May 25, 2011