- 8 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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