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York counties of Bronx, Kings, New York (boroughs of Brooklyn and
Manhattan), Queens, and Richmond, or is in Arlington County,
Virginia, where the Pentagon is located; (2) victims of the crash
(including those on a plane and those on the ground) of the four
commercial jet airplanes hijacked on September 11, 2001; (3) all
workers assisting in the relief activities in the covered
disaster areas and in Pennsylvania; (4) taxpayers who work in the
presidentially declared disaster area; and (5) taxpayers who have
difficulty in filing returns or making payments because of
disruptions in the transportation and delivery of documents by
mail or private delivery services resulting from the terrorist
attack. Petitioners’ activities in Hawaii do not qualify them as
relief workers assisting in a covered disaster area (category
(3)). Thus, petitioners do not qualify as affected taxpayers
under any of these categories.
Respondent also provided to another category of taxpayers a
postponement of up to 14 days of certain tax deadlines, including
filing a Tax Court petition. Notice 2001-63, supra, states in
pertinent part:
This notice provides additional tax relief under
sections 6081, 6061, and 7508A for taxpayers who,
regardless of their location, are continuing to
experience difficulties in meeting their filing and tax
payment requirements on account of events related to
the September 11, 2001, terrorist attack. The Internal
Revenue Service has determined that the due date for
all federal tax obligations falling between September
10, 2001, and September 24, 2001, is postponed to
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