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Thereafter, by Order dated December 29, 2006, the Court
directed petitioner to supplement his Notice Of Objection by
setting forth who prepared the petition, who placed the
petition in the mail, the location where the petition
was deposited into the mail, and the circumstances
surrounding the purported mailing of the petition to
the Tax Court on or before October 5, 2006, which
petitioner appears to allege in numbered paragraph 1.
of his Objection and * * * attach to that supplement
copies of any documents establishing the timely mailing
of the petition to the Court on or before October 5,
2006.
On January 23, 2007, petitioner responded to the
aforementioned Order by filing a Supplement To Objection. In it,
petitioner states as follows:
The petition was prepared by myself, Ronald S.
Raczkowski. I placed the petition in the mail at the
Estes Road post office on the evening of October 5,
2006. The mail apparently did not get picked up until
October 6, 2006. I do not have any documents which
establish the above situation.
A hearing on respondent’s motion was held in Washington,
D.C., on March 7, 2007. At that time, counsel for respondent
appeared and argued in support of the pending motion. In
contrast, there was no appearance by or on behalf of petitioner,
nor did petitioner file a written statement pursuant to Rule
50(c), the provisions of which were noted by the Court in its
Order calendaring respondent’s motion for hearing.
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Last modified: November 10, 2007