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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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