- 3 -
sent. On August 18, 2006, the USPS affixed a label bearing that
day's date and the Pittsfield address to the envelope containing
the notice, and forwarded the notice to the Pittsfield address.
Petitioner admits that he received the notice of deficiency on
August 30, 2006, 75 days before the statutory deadline for filing
a petition in this Court with respect to the notice of deficiency
(November 13, 20062).
Petitioner prepared and signed a petition using this Court's
one-page petition form (T.C. Form 2). Paragraph 4 of the form
petition, which permits the taxpayer to "Set forth the relief
requested and the reasons why you are entitled to such relief",
had an entry of six sentences.
The petition was undated. Petitioner used a private
delivery service, FedEx, to deliver his petition to the Court.
The FedEx envelope which contained the petition bears an
electronically generated label with a "Ship Date" denoted as
November 14, 2006, and the notation "Standard Overnight". The
petition was received and filed by the Court on November 15,
2006.
2 The 90th day after the Aug. 14, 2006 mailing of the notice
of deficiency was Nov. 12, 2006, which was a Sunday. The notice
of deficiency also stated that the last day on which to file a
petition with this Court was Nov. 13, 2006.
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: November 10, 2007