- 2 - that we lack jurisdiction because the notice of deficiency was invalid. Further, petitioners argue that respondent is barred from proceeding in this case because the 3-year statute of limitations period provided by section 6501(a) expired. Background At the time of filing the petition, petitioner Meilute Biskis resided in Downers Grove, Illinois. All references to petitioner are to Meilute Biskis. Kestutis Biskis (Mr. Biskis) and petitioner jointly filed their Federal income tax return for taxable year 1995 on October 17, 1996. Mr. Biskis died on May 28, 1997, in Lithuania. On September 8, 1999, petitioner submitted to respondent Form 2848 (Power of Attorney and Declaration of Representative) appointing Vytautas Vebeliunas, an accountant, to represent petitioner and the estate of Mr. Biskis for taxable year 1995. Petitioner requested that Mr. Vebeliunas receive all original communications from respondent, and all copies should be sent to petitioner. On September 30, 1999, Ms. Winslow, an Internal Revenue Service (IRS) tax auditor, notified petitioners and Mr. Vebeliunas that petitioner had failed to file Form 56 (Letter of Testamentary and Death Certificate) which was required to validate Form 2848 as to the estate of Mr. Biskis. 1(...continued) and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011