- 3 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011