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respondent’s deficiency determinations.2 The petition is dated
October 5, 2001. The petition arrived at the Court in an
envelope bearing U.S. Postal Service certified mail No. 7001 0360
0001 7533 5423 and two postmarks. One of the postmarks is a
private postmeter postmark showing Bellflower, California, as the
postal locale, and the other is a U.S. Postal Service postmark
showing Long Beach, California, as the postal locale. Both
postmarks are dated October 5, 2001.
As indicated, respondent filed a motion to dismiss for lack
of jurisdiction on the ground that the petition was not timely
filed. Petitioners filed an objection to respondent’s motion to
dismiss, alleging that they initially mailed a petition to the
Court on September 15, 2001, and, after they received no response
from the Court, they mailed a second petition to the Court on
October 4, 2001.3 Petitioners’ objection suggests that the
2 The body of the petition, which is essentially a letter
to the Tax Court, reads as follows:
Tax Court;
This letter represents a formal request for petition
forms needed to file with the court.
See attached “Notice Of Deficiency” letter dated July
6, 2001, giving us the 90 days to file the petition
forms.
Please send forms to: Juan El Khouri
[address]
3 In response to petitioners’ allegation regarding the
(continued...)
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