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Background
At the time the petition was filed, petitioners resided in
Meridian, Idaho.
Petitioners timely filed their 2001 joint Federal income tax
return. On June 16, 2003, respondent mailed to petitioners the
notice of deficiency.
On June 21, 2003, petitioners mailed to the Court by
certified mail a three-page letter, which was filed by the Court
as petitioners’ petition (original petition). With the original
petition, petitioners did not submit the $60 Court filing fee
that was due. Rule 20(b). The envelope in which the original
petition was mailed is in evidence, and a postage cost therefor
of $4.65 is indicated on the envelope.
On August 26, 2003, petitioners mailed to the Court by
certified mail an amended petition, in proper form, and included
the $60 filing fee.
On or about March 19, 2004, after various communications
with petitioners,2 respondent conceded the $728 tax deficiency
determined against petitioners, and petitioners mailed to
respondent’s Portland office by certified mail a letter in which
petitioners set forth their claim for litigation costs.
On April 19, 2004, at a cost of $15.95, petitioners
delivered to the Court via Federal Express their motion for an
award of litigation costs with an attached expense report
2 The nature of these referenced communications is not
reflected in the record, and petitioners claim no costs relating
thereto.
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Last modified: May 25, 2011