- 5 -
day period for filing had elapsed. Petitioners cited a series of
problems, including: (1) Mr. Caple’s terminal illness,5 (2) the
death of Mr. Caple’s father in February 1997, (3) two “stressful
lawsuits” of an unspecified nature, and (4) petitioners’ “severe”
financial problems.
On September 3, 1997, the Court issued to petitioners a
notice of filing by respondent of a motion to dismiss for lack of
jurisdiction. Petitioners were required by the notice of filing
to file an objection to respondent’s motion to dismiss within 20
days; they failed to do so. On October 8, 1997, the Court
granted respondent’s motion to dismiss.
Respondent assessed petitioners’ Federal income tax owed for
taxable years 1993 and 1994, together with interest and
penalties, on June 23, 1997. Respondent’s statements of account
show that from the date the assessment was made, there occurred a
series of payments, credits, additional assessments, and
adjustments with respect to both taxable years at issue. As of
May 31, 2004, the date on which petitioners requested that a copy
of respondent’s statements be mailed to them, the transcripts
showed a zero balance remaining for taxable year 1993 and a
balance remaining (including interest and penalties) of
$21,606.92 for taxable year 1994.
5 Mr. Caple was told by his doctors in 1996 that he had only
2 years to live.
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Last modified: March 27, 2008