- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007