Gerry Dan and Kelly M. Langston - Page 2

                                                - 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                                

Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011