Wayne D. Blake - Page 2




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               Petitioner resided in Baltimore, Maryland, at the time the             
          petition was filed.                                                         
               On October 16, 2006, respondent mailed to petitioner by                
          certified mail to his last known address, which is also his                 
          address of record in this case, a notice of deficiency with                 
          respect to his taxable year 2000 (2000 notice).                             
               On January 22, 2007, the Court received a petition with                
          respect to the 2000 notice.1  Barry L. Dahne (Mr. Dahne), peti-             
          tioner’s counsel of record in this case, signed the petition.               
          Included in the envelope in which the petition was mailed to the            
          Court was a check for $60 drawn on the account of Barry L. Dahne            
          that was signed by him, made payable to “US TAX COURT”, and dated           
          “1/16/2007” (January 16, 2007 check).  The Court used that check            
          to pay the $60 filing fee required by Rule 20(b),2 and on January           
          22, 2007, at 11:35 a.m., issued a receipt for that payment that             
          it sent to Mr. Dahne.                                                       
               The envelope containing the petition and Mr. Dahne’s January           
          16, 2007 check that the Court received bore four first-class                
          stamps that were not canceled.  That envelope did not bear a U.S.           
          Postal Service postmark.  Nor did it bear a privately metered               


               1The Court filed the petition at 10:56 a.m. on Jan. 22,                
          2007.                                                                       
               2All Rule references are to the Tax Court Rules of Practice            
          and Procedure.  All section references are to the Internal                  
          Revenue Code in effect at all relevant times.                               






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