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designation of place of trial had not been received.4 See Rule
140.
On June 25, 1996, the Court received and filed a Designation
of Place of Trial (DPT), a simple, one-page document that
designated Chicago, Illinois, as the place of trial. The DPT was
signed and dated by James.5 The Court served the DPT on
petitioner at its Highland Park office in order to confirm the
receipt and filing of the document.
On July 9, 1996, respondent served his answer to the
petition, see Rule 36, by mailing a copy to petitioner at its
Highland Park office. The envelope containing the answer was
delivered to petitioner and opened by James. James printed
“Attn: Steve Jaffe” in the upper right corner of the answer and
placed it in the box in his office reserved for Jaffe’s use.
On October 17, 1996, the Court sent petitioner a Notice
Setting Case For Trial (the trial notice). The trial notice
was mailed to petitioner at its Highland Park office by certified
mail. The trial notice served to notify petitioner that its Tax
Court case had been calendared for trial at the Trial Session
4 Consistent with its regular practice, the Court enclosed
with the notification, for petitioner’s use, the form designed to
designate a place of trial. See Form 5 in Appendix I to the Tax
Court Rules of Practice and Procedure.
5 It was Jaffe, however, and not James who printed
“Chicago, Illinois” on the DPT and added “Vice President”
immediately to the right of James’ signature.
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Last modified: May 25, 2011