- 3 - The notice of determination informed petitioner that if he wanted to dispute respondent’s determination in court, then he must file a petition with this Court “within 30 days from the date of this letter.” On November 13, 2002, petitioner purchased a U.S. Postal Service Postal Money Order in the amount of $60. The Postal Money Order was payable to “United States Tax Court” and was purchased to pay the filing fee for commencing a lien or levy action in this Court. See Rule 331(c). Petitioner listed his address on the Postal Money Order as the P.O. box address. On Friday, November 29, 2002, the Court received and filed a Petition for Lien or Levy Action Under Code Section 6320(c) or 6330(d). The petition, which is undated, arrived at the Court in a properly addressed envelope that identifies the P.O. box address as the return address.2 Significantly, the envelope, which was mailed to the Court by U.S. Postal Service Express Mail, bears a legible postmark date of Wednesday, November 27, 2002.3 Shortly after this case was calendared for trial, respondent moved to dismiss the petition for lack of jurisdiction on the 2 In contrast, petitioner used his street address on the petition itself. 3 We note that Thursday, Nov. 28, 2002, was Thanksgiving Day, a legal holiday in the District of Columbia, see Rule 25(b), and that there was no mail delivery to the Court on that day.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011