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On August 27, 2001, petitioner timely mailed his petition
with the Court in response to the July 26, 2001, notice of
determination; the Court received and filed the petition on
September 4, 2001.7
Discussion
As a preliminary matter, we note that petitioner’s mail and
living arrangements, which have created and continue to create
difficulties in contacting him, and his repeated failures to
comply with deadlines, have impeded and delayed respondent’s
collection efforts and the efforts of the Court to resolve these
matters.
We note that petitioner has uttered contradictory testimony
and arguments and has failed to provide respondent and the Court
with reliable information and documents to resolve this matter.
Petitioner bears the risk of loss and the responsibility arising
from failure to prepare and file returns and to preserve and
locate his cost records and copies of prior returns for use in
substantiating items required to be reported on his returns for
the years in issue.
7Petitioner’s mailing of the petition was a timely filing on
the last day of the 30-day period specified by secs. 6320(c) and
6330(d), as extended by Rule 25. Aug. 25 and 26, 2001, were a
Saturday and Sunday, respectively, and petitioner mailed the
petition on Monday, Aug. 27, 2001. See Guerrier v. Commissioner,
T.C. Memo. 2002-3.
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