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OPINION OF THE SPECIAL TRIAL JUDGE
ARMEN, Special Trial Judge: This matter is before the
Court on respondent's Motion to Dismiss for Lack of Jurisdiction.
The issue for decision is whether the petition was filed within
the 90-day period prescribed in section 6213(a).
Background
On October 23, 1997, respondent mailed a notice of
deficiency to Tim R. Casanova and San Juanita Villareal
(petitioners) determining a deficiency in, and an accuracy-
related penalty on, their income tax for 1993. On January 21,
1998, petitioners filed an imperfect petition with the Court,
assigned docket No. 1418-98. By Order dated January 27, 1998,
the Court provided petitioners with a blank form petition and
directed them to file a proper amended petition and pay the
required $60 filing fee in docket No. 1418-98.
On February 19, 1998, respondent mailed a notice of
deficiency to petitioners determining deficiencies in, and
accuracy-related penalties on, their income taxes for 1994, 1995,
and 1996 as follows:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1994 $19,833 $3,893.20
1995 14,715 2,906.00
1996 12,217 2,443.40
On February 25, 1998, the Court received an envelope from
petitioners containing the following documents pertaining to
docket No. 1418-98: (1) A partially completed form amended
petition; (2) 3 copies of a designation of place of trial
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