- 3 - The notices were sent to petitioners by certified mail, and petitioner wife signed for each on December 20, 2001. Each notice was date stamped “DEC 18 2001" in the upper left hand corner next to the word “Date”. Vertically listed in the upper right hand corner of each notice were various items of information, including information regarding the person to contact at the Internal Revenue Service and a telephone number to call. The last item was the subject matter of the notice: “In Re: Due Process Appeal (Tax Court)”. Each notice bore a second date stamp, “FEB 16 2002", immediately under or next to that last information item. Each notice also contained the following sentence (comprising a separate paragraph) in the body of the notice: If you want to dispute this determination in court, you must file a petition with the United States Tax Court for a redetermination within 30 days from the date of this letter. Each notice also contained the following language: The time limit for filing your petition is fixed by law. The courts cannot consider your case if you file late. * * * Petitioners waited until January 23, 2002, to inquire about the significance of the two dates stamped on the notices. On that date, petitioner husband inquired of Appeals Officer Dianne Villa about such significance. Ms. Villa informed him that he had only 30 days from the date of the notices to appeal to the Tax Court and that the February 16 date was probably an internalPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011