Juan El Khouri and Kitty Hunter - Page 3




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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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