- 6 -
This matter was called for hearing at the Court's motions
session in Washington, D.C., on October 14, 1998. Counsel for
respondent appeared at the hearing and provided the Court with a
copy of Postal Service Form 3849 demonstrating that the notice of
deficiency for 1994, 1995, and 1996 was delivered on February 20,
1998.4 There was no appearance at the hearing by or on behalf of
petitioners. During the hearing, the Court made the following
exhibits part of the record in this case: (1) The envelope that
petitioners mailed to the Court on February 20, 1998, bearing
registered mail No. R773-219-004; (2) the deputy clerk's
February 26, 1998, letter to petitioners; and (3) the Court's
retained copy of Postal Service Form 1000.
By Order dated October 14, 1998, petitioners were given the
opportunity to file a second supplemental objection to
respondent's motion. On November 13, 1998, petitioners filed a
second supplemental objection to respondent's motion in which
they denied receiving the deputy clerk's February 26, 1998,
letter and suggested that the Court had mistakenly filed the
contents of the envelope that they mailed to the Court on
February 20, 1998, under docket No. 1418-98S.
This matter was called for further hearing at the Court's
motions session in Washington, D.C., on November 25, 1998.
Counsel for respondent appeared at the hearing and presented
4 Postal Service Form 3849 indicates that the notice of
deficiency was received by a Linda Perez, whom we understand to
be petitioners' employee.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011