- 4 -
The first deficiency notice was addressed to the law offices
of Neal Sanders at "106 S. Main St., Ste. 808, Butler, PA 16001".
The second deficiency notice was addressed to Neal Sanders at "118
Hickory Hills, Slippery Rock, PA 16057" (the Hickory Hills
address), and the third deficiency notice was addressed to Neal
Alan and Linda Sanders at the Hickory Hills address.
On January 2, 1997, Neal A. Sanders, d.b.a. Law Offices of
Neal A. Sanders (petitioner), filed a petition in this Court2 in
which he contested respondent's determinations relating to "excise
taxes and penalties in an accumulated amount in excess of $10,000
* * * for the years 1991, 1992, 1993, 1994 and 1995." Attached to
the petition were copies of the first deficiency notice only.
The 90-day period for filing a petition with respect to each
of the three notices of deficiency expired on January 9, 1997,
which was not a Saturday, Sunday, or legal holiday in the District
of Columbia.
On June 5, 1997, petitioner filed an amended petition in which
he disputed the income tax deficiencies determined against Neal
2 The petition was captioned "Neal A. Sanders, d.b.a. Law
Offices of Neal A. Sanders, Law Offices of Neal A. Sanders
Pension Plan, and Law Offices of Neal A. Sanders Profit Sharing
Plan, by Plan Administrator, Neal A. Sanders." On Feb. 27, 1997,
respondent filed a Motion to Dismiss for Lack of Jurisdiction as
to Law Offices of Neal A. Sanders Pension Plan and Law Offices of
Neal A. Sanders Profit Sharing Plan and to Change Caption. On
July 7, 1997, we granted respondent's motion and ordered the
caption of this case changed to read "Neal A. Sanders, d.b.a. Law
Offices of Neal A. Sanders, Petitioner v. Commissioner of
Internal Revenue, Respondent."
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011