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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.
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