Rochelle v. Commissioner

The Commissioner of Internal Revenue issued a statutory notice of deficiency to the taxpayer, James A. Rochelle, determining federal income tax deficiencies for 1995 and 1996, together with accuracy-related penalties. The notice showed the mailing date, but failed to show, under the appropriate heading, the last day to file a petition with the United States Tax Court. See Internal Revenue Service Restructuring and Reform Act of 1998, Pub.L. No. 105-206, § 3463(a), 112 Stat. 685, 767 (requiring each notice of deficiency to include “the last day on. which the taxpayer may file a petition with…