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E. The Tax Court Proceeding
On March 15, 1996, respondent’s Milwaukee Appeals Office
mailed a notice of deficiency to petitioner. The notice was
addressed to petitioner at its Highland Park office. The notice
determined deficiencies in petitioner’s Federal income taxes and
accuracy-related penalties under section 6662(c) as follows:
Accuracy-related Penalty
I.R.C.
Year Deficiency Sec. 6662
1990 $66,194 $53,620
1992 129,526 25,905
1993 96,884 22,048
On June 14, 1996, a petition was filed with this Court
disputing the deficiencies and penalties determined by respondent
in the notice of deficiency. The petition was purportedly signed
by John in his capacity as petitioner’s president. However, the
petition was actually signed by Jaffe. Jaffe had not been
expressly authorized by John to sign John’s name on the petition.
On June 17, 1996, the Court sent petitioner a Notification
of Receipt of Petition (notification). The notification was
mailed to petitioner at its Highland Park office. The
notification served to confirm the receipt of a petition, its
filing date, and the payment of the filing fee. The notification
also disclosed the docket number that had been assigned by the
Court to the petition. Finally, the notification advised that a
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