- 4 - Ashley’s care that were not otherwise covered by their insurance.4 Petitioners’ 1993 and 1994 Taxable Years In taxable years 1993 and 1994, petitioners sold Wal-Mart stock for $57,400 and $56,650, respectively. Petitioners failed to report the proceeds from either sale on their 1993 or 1994 Federal income tax return. Respondent commenced an examination of petitioners’ 1993 and 1994 Federal income tax returns. Following notice that these returns had been selected for examination, petitioners promptly contacted respondent’s Appeals Office; they were unable to reach a mutually satisfactory resolution to the matter of petitioners’ unreported income. On December 6, 1996, respondent sent petitioners a notice of deficiency for taxable years 1993 and 1994. The notice of deficiency was sent to petitioners’ current address, and it informed petitioners of their right to file a petition for redetermination with the Court no later than 90 days from the date of mailing. Petitioners filed a petition with the Court on July 8, 1997, citing a series of “extra-ordinary [sic] circumstances that prevented [them] from filing” before the 90- 4 Aside from petitioners’ testimony regarding Ashley’s various medical conditions, and proof of their insurance, the record is devoid of any evidence substantiating the costs petitioners actually incurred with respect to Ashley’s medical expenses.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008