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right corner of the document, immediately opposite “UNITED STATES
TAX COURT” and immediately above “Docket No. 12390-96". At
trial, James admitted that he bears responsibility for reading
his mail. He also bears responsibility for reading his mail with
reasonable care. By placing respondent’s answer in the box in
his office reserved for Jaffe’s use, James obviously knew that
the document was tax related. At the very least, James saw, or
should have seen, the Tax Court designation and knew, or should
have known, that the case had escalated beyond the audit phase.
See id. James’ act of opening the envelope, annotating
respondent’s answer, and then forwarding it to Jaffe constituted
a ratification of the filing of the petition.
Third, John signed and dated the stipulated decision. The
decision is a relatively straightforward, two-page document that
sets forth the amount of the tax deficiencies and accuracy-
related penalties for which petitioner is liable. The words
“UNITED STATES TAX COURT” appear prominently at the top of the
first page, followed by the caption and docket number, which
together clearly indicate that the document pertains to a court
case. Immediately below the signature line on the second page of
the decision was the typewritten designation:
JOHN W. GIBBS, PRESIDENT
TRANS WORLD TRAVEL
Petitioner
which also indicated that the document pertained to a court case.
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