Robert and Diana Roberts - Page 3

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               Respondent determined the following deficiencies, additions            
          to tax, and penalties for each year:                                        
                                   Additions to Tax     Penalties                     
          Year      Deficiency          Sec. 6651(a)(1)     Sec. 6662(a)              
          1991      $32,847             $8,011              $6,409                    
          1992      7,978               1,881               1,545                     
          1993      5,612               1,403               1,122                     

          The notice of deficiency states in pertinent part:                          
                    If you want to contest this determination in court                
               before making any payment, you have 90 days from the                   
               date of this letter (150 days if addressed outside the                 
               United States) to file a petition with the United                      
               States Tax Court for a redetermination of the                          
               deficiency.  You can get a copy of the rules for filing                
               a petition and a petition form you can use by writing                  
               to the address below.                                                  
                               United States Tax Court                                
                                400 Second Street, NW                                 
                                Washington, DC 20217                                  
               Upon receipt of the notice of deficiency at his office on              
          August 2, 1997, petitioner opened and read the notice.  He then             
          called his accountant and advised the accountant of its receipt.            
          Pursuant to that communication, the accountant picked up the                
          notice from petitioner's business office soon thereafter.  On               
          August 3, 1997, petitioner left the United States for Akumal,               
          Mexico.  He returned to the United States on November 4, 1997.              
               While petitioner was in Mexico, his accountant prepared the            
          petition.  Petitioner periodically talked with his wife and                 
          persons in his office while he was away; however, he did not have           
          any conversations relating to the notice of deficiency or the               





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