- 2 - 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 trialPage: Previous 1 2 3 4 5 6 7 8 9 Next
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