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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.
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