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respondent sent Mrs. Godwin by certified mail a notice of
determination under section 6330 (the Linda Godwin notice). In
the section 6330 cases, petitioner filed a petition for
redetermination on September 10, 2001, and both petitioners filed
a petition for redetermination on September 13, 2002.4
On November 9, 2001, respondent sent petitioners by
certified mail a notice of deficiency for their 1997 tax year for
a deficiency attributable to the disallowance of claimed casualty
losses from the 1997 earthquakes, Hurricane Danny, and Hurricane
Georges and for a section 6651(a)(1) addition to tax. On January
7, 2002, petitioners filed a joint petition for redetermination
in the deficiency case.
The section 6654(a) and 6651(a)(1) and (2) additions to tax
in the section 6330 cases and the section 6651(a)(1) addition to
tax in the deficiency case are now in dispute.
OPINION
Our ultimate finding, notwithstanding the natural disasters
and the changes in clerical and bookkeeping personnel at
petitioner’s law office, is that petitioners did not exercise due
4Respondent moved to dismiss for lack of jurisdiction as to
Mrs. Godwin under docket No. 11382-01L because of issues
regarding petitioner’s authority to represent her. We granted
respondent’s motion, which was thereafter rendered moot by
petitioner’s admission to practice before this Court, and
respondent’s sending Mrs. Godwin a notice of determination under
sec. 6330, in response to which petitioner filed a petition with
the Court on behalf of Mrs. Godwin in docket No. 14817-02L.
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Last modified: May 25, 2011