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The September 11, 2001, terrorist attack is a presidentially
declared disaster for purposes of sections 7508(a) and 7508A.
Notice 2001-61, 2001-40 I.R.B. 305; Notice 2001-63, 2001-40
I.R.B. 308. Petitioners contend that they are “affected
taxpayers”, i.e., taxpayers affected by the September 11, 2001,
terrorist attack, as defined in section 301.7508A-1(d)(1),
Proced. & Admin. Regs., and Notice 2001-61, supra. Section
301.7508A-1(d)(1), Proced. & Admin. Regs., and Notice 2001-61,
supra, define affected taxpayers for purposes of section 7508A.
The regulations under section 7508A describe categories of
taxpayers who are generally affected by presidentially declared
disasters. Notice 2001-61, supra, describes categories of
taxpayers who were specifically affected by the September 11,
2001, terrorist attack.
Under section 301.7508A-1(d)(1), Proced & Admin. Regs.,
affected taxpayers include:
(i) Any individual whose principal residence * * *
is located in a covered disaster area;
(ii) Any business entity or sole proprietor whose
principal place of business is located in a covered
disaster area;
3(...continued)
(a) Time to be disregarded.--
* * * * * * *
(C) Filing a petition with the Tax Court
for redetermination of a deficiency * * *.
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Last modified: May 25, 2011