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to file a petition in the Tax Court was extended from September
25, 2001, to October 3, 2001, by relief provisions promulgated by
respondent for taxpayers affected by the September 11, 2001,
terrorist attack. We hold that it was not.
Section references are to the Internal Revenue Code as
amended. References to petitioner are to Timothy Scott Anthony.
Background
Petitioners resided in Kailua, Hawaii, when they filed their
petition. The records necessary to prepare petitioners’ petition
were in Hawaii during all relevant times. On June 27, 2001,
respondent sent a notice of deficiency for 1999 to petitioners at
their last known address. The 90th day after the notice of
deficiency was issued, and thus the last date for petitioners to
timely file a petition in the Tax Court without regard to relief
provisions, was September 25, 2001. See sec. 6213(a).
Between September 11, 2001, and when they mailed their
petition on October 3, 2001, petitioners did volunteer work in
Hawaii for an organization known as Stand Up For America,1 which
was organized in Hawaii to memorialize the victims of the
September 11, 2001, terrorist attack. Petitioner’s wife
coordinated other volunteers, arranged for a website, obtained
flowers, and kept a bank account for Stand Up For America.
1 The record is silent regarding the specific activities of
Stand Up For America.
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