- 2 -
Background
At the time he filed his petition and amended petition,
petitioner resided in Syracuse, New York.
In the notice of deficiency, dated September 4, 2001,
respondent determined a deficiency in petitioner’s 1999 Federal
income tax of $5,028.2 The notice of deficiency advised
petitioner that he had 90 days from the date of the notice to
file a petition in the Tax Court for a redetermination of the
deficiency. The notice of deficiency stated that the last date
to petition the Tax Court was December 3, 2001.
Petitioner mailed a petition properly addressed to the Court
in late November 2001 at a post office in the Carousel shopping
mall in Syracuse after he finished work. The Court received the
petition on January 2, 2002, which is 120 days after the mailing
of the notice of deficiency. In November and December 2001 and
January 2002, the Court was experiencing significant anthrax-
related mail delays following the closure of the post office
serving the Court. In January 2002, the Court was still
receiving mail from November and December 2001. All of the
regular U.S. mail received by the Court was subject to
irradiation treatment. As a result of the irradiation treatment,
1(...continued)
are to the Tax Court Rules of Practice and Procedure.
2 Amounts are rounded to the nearest dollar.
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011