Nemat Mostaan - Page 3

                                        - 3 -                                         
                 Additions to Tax                                                     
          Year     Deficiency     Sec. 6651(a)(1)     Sec. 6654                       
          1986        $887             $222              $42                          
          1987      17,962            4,491              968                          
          1988       5,052            1,263              324                          
          Petitioner mailed a petition in this case by certified mail                 
          on June 23, 1995 (91 days after the mailing of the notice of                
          deficiency) and it was received by this Court on June 27, 1995              
          (95 days after the mailing of the notice).                                  
          The jurisdiction of this Court is governed by statute.  Sec.                
          7442.  In order to maintain an action in this Court there must be           
          a valid notice of deficiency and a timely filed petition.  Rule             
          13(a), (c); Monge v. Commissioner, 93 T.C. 22, 27 (1989); Abeles            
          v. Commissioner, 91 T.C. 1019, 1025 (1988).  Under section 6212,            
          a notice of deficiency is sufficient if it is mailed to the                 
          taxpayer's last known address by certified or registered mail.              
          Sec. 6212(a) and (b).  A notice of deficiency will be deemed                
          valid, whether or not received by the taxpayer, if it was mailed            
          to the taxpayer's last known address.  Tadros v. Commissioner,              
          763 F.2d 89, 91 (2d Cir. 1985); Frieling v. Commissioner, 81 T.C.           
          42, 48, 52 (1983).  In general, a petition must be filed with the           
          Tax Court within 90 days from the date a statutory notice of                
          deficiency is mailed to a taxpayer residing in the United States.           
          Sec. 6213(a).  If a petition is not filed within the 90-day                 
          period, this Court does not acquire jurisdiction of the case.               
          Cataldo v. Commissioner, 60 T.C. 522 (1973), affd. per curiam 499           
          F.2d 550 (2d Cir. 1974).  Moreover, an improperly addressed                 




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