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by section 6213(a) or section 7502.1 As explained below, we
shall grant respondent’s motion to dismiss.
Background
Petitioner resided in Chapel Hill, North Carolina, when the
petition was filed in this case.
On Friday, July 7, 2006, respondent mailed a notice of
deficiency to Ronald S. Raczkowski (petitioner). In the notice,
respondent determined deficiencies in petitioner’s Federal income
taxes for the taxable years 2003 and 2004 in the amounts of
$40,634 and $7,994, respectively. The notice was sent to
petitioner by certified mail at his home address. Petitioner
received the notice of deficiency on Tuesday, July 11, 2006.
The first page of the notice of deficiency states as
follows: “Last Day to File a Petition With The United States Tax
Court: October 5, 2006”.
On Tuesday, October 10, 2006, petitioner filed a petition
with this Court seeking a redetermination of the deficiencies
determined by respondent in the notice of deficiency. The
petition, which is dated Friday, October 6, 2006, was delivered
to the Court by United Parcel Service of America, Inc. (UPS), a
private delivery service (PDS), in an “Express Pad Pak”
indicating that it had been sent by “UPS Ground” service.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time that the petition
was filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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