- 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