- 2 - determining a deficiency of $31,970 in their Federal income tax for 1992. Respondent mailed the notice to petitioners at their last known address; namely, 6806 Selkirk Drive, Bethesda, Maryland 20817. Petitioner Michael H. Selter is a partner in a law firm located in Washington, D.C. On Wednesday, March 8, 2000, at approximately 8 a.m., the Tax Court mailroom received an envelope containing the Selters' petition contesting the notice of deficiency described above. The envelope bears a preprinted address label listing the name and address of Mr. Selter's law firm as the sender, and the envelope identifies the Court as the addressee.1 Notably, the envelope does not bear any postage, nor does it bear any type of postmark. There is no adhesive or sticky residue in the upper right-hand corner of the envelope, suggesting that postage may never have been affixed thereto. Further, the envelope is not torn, damaged, or unusually soiled, nor does it appear to have been abused, and there are no marks or notations on the envelope indicating that it was misdirected or otherwise delayed in transit. Affixed to the envelope are a certified mail receipt 1 Although the Court's ZIP Code was erroneously listed on the address label as 20817 (the ZIP code for the Selters’ home address in Bethesda, Maryland) rather than the Court’s correct ZIP Code of 20217, a representative of the U.S. Postal Service testified that such an error would not have delayed the delivery of the petition to the Court. See also Price v. Commissioner, 76 T.C. 389 (1981).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011