Juan El Khouri and Kitty Hunter - Page 12




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          the period beginning on September 11, 2001, and ending on                   
          November 30, 2001.                                                          
          Notice 2001-63                                                              
               In Notice 2001-63, 2001-40 I.R.B. 308, released September              
          15, 2001, the Commissioner announced additional relief under                
          sections 7508A, 6081, and 6161, for all taxpayers regardless of             
          their location.  In particular, Notice 2001-63 states in                    
          pertinent part:                                                             
               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 September 24, 2001.  This postponement of                 
               time covers the filing of returns and claims for                       
               refund, the payment of tax (including estimated tax                    
               payments), making elections, and filing any other                      
               Federal tax documents.  The postponement does not apply                
               to deposits of federal taxes. * * * [Emphasis added.]                  
          Notice 2001-68                                                              
               Finally, in Notice 2001-68, 2001-47 I.R.B. 504, released               
          November 10, 2001, the Commissioner announced additional relief             
          to supplement the relief granted in Notice 2001-61.  As relevant,           
          Notice 2001-68 states in pertinent part:                                    
               C. ADDITIONAL GRANT OF RELIEF                                          
                  *       *       *       *       *       *       *                   
               (2)  Under paragraph (4) of the Grant of Relief section                
               of Notice 2001-61, the IRS granted to all affected                     
               taxpayers a 120-day postponement of time to perform the                
               acts described in section 301.7508A-1(c)(1), [Proced. &                
               Admin. Regs.,] if the last day to perform the act fell                 
               within the period beginning on September 11, 2001, and                 
               ending on November 30, 2001.  One of these acts is the                 
               filing of any Tax Court petition.  Under this notice,                  





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