- 4 - At the Appeals Office collection hearing (and herein) petitioner claimed that in February of 2005 when she received respondent’s deficiency notice charging her with an additional $88,000 in income, she began to suspect that $88,000 may have been stolen or embezzled from her and received by someone else. Accordingly, petitioner explains, rather than file a Tax Court petition to contest respondent’s deficiency determination, upon receipt of the notice of deficiency petitioner contacted a local California police department and requested an investigation as to whether $88,000 had been stolen from her. As part of the police investigation that was begun, petitioner delivered to the police approximately 100 pages of personal documents, apparently including the original of respondent’s notice of deficiency to petitioner and the Forms 1099-B that petitioner had received. Petitioner explains further that she did not make copies of the documents, including the notice of deficiency, and therefore that once she turned the documents over to the police--in early March of 2005 and until early 2006 when they were returned to her--she did not have access to the documents. Because--for much of the 90-day period allowed under section 6213(a) for the filing of a Tax Court petition--the original of respondent’s notice of deficiency to petitioner was in the possession of the police, petitioner in this collection action asserts that she should be excused for her failure to file aPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007