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the relief provided by paragraph 4 is expanded as
follows. If the last date for filing any Tax Court
petition would otherwise be on or after December 1,
2001, and on or before December 31, 2001, the last date
for filing the petition is postponed by 60 days under
section 7508A.
In short, Notice 2001-68 expanded the period during which an
affected taxpayer would be permitted to file a petition with the
Court.
Based upon our review of section 7508A, section 301.7508A-1,
Proced. & Admin. Regs., and Notices 2001-61, 2001-63, and 2001-
68, we conclude that petitioners are not entitled to relief with
regard to the late-filed petition in this case. Petitioners, who
are residents of southern California, have not alleged or shown
that they are “affected taxpayers” within the meaning of section
301.7508A-1(d)(1)(i)-(vi), Proced. & Admin. Regs., or Notices
2001-61 and 2001-68. Moreover, the generic relief extended to
all taxpayers in Notice 2001-63, see section 301.7508A-
1(d)(1)(vii), Proced. & Admin. Regs., is of no benefit to
petitioners. The latter Notice states that the deadline for all
Federal tax obligations falling between September 10, 2001, and
September 24, 2001, is postponed to September 24, 2001. Because
the deadline for filing a timely petition in this case expired on
October 4, 2001, it follows that such deadline is not postponed
under Notice 2001-63.
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