- 3 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011