Yvonne Thomas - Page 4
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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 a
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Last modified: November 10, 2007