3
Wisconsin, 53203, to Beloit, Wisconsin, 53512, typically takes 2
days for delivery.
Petitioners were in the United States on December 2, 1997,
the date the notices of deficiency were mailed to petitioners.
Petitioners also were in the United States on December 5, 1997,
the date on which the notices of deficiency would typically have
been delivered to them through certified mail. Petitioners were
in the United States on March 2, 1998, the 90th day after mailing
of the notices of deficiency.
Petitioners were out of the country for the period from
February 4, 1998 to February 25, 1998.
The 90-day period for timely filing a petition with this
Court expired on Monday, March 2, 1998, which date was not a
legal holiday in the District of Columbia. The petition was
filed with the Tax Court on March 17, 1998. This date was 105
days after the mailing of the notices of deficiency.
The record shows that the envelope containing petitioners'
petition was mailed via the U.S. Postal Service on March 14,
1998. This date was 102 days after the mailing of the notices of
deficiency.
A petition for redetermination of a deficiency must
generally be filed with this Court within 90 days after the
notice of deficiency is mailed to the taxpayer. Sec. 6213(a).
If the notice "is addressed to a person outside the United
States" the taxpayer would have 150 days to file. Id. If a
taxpayer fails to file within the statutory period, the petition
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