Trans World Travel - Page 8




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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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