Scaggs v. Comm'r
United States Tax Court
R mailed a notice of deficiency to Ps on Apr. 8, 2011. The 90th day after respondent mailed the notice of deficiency was Thursday, July 7, 2011, which was not a legal holiday in the District of Columbia. The petition was received by the Court and filed on July 12, 2011. The envelope in which the petition was received bears a Federal Express (FedEx) U.S. Airbill dated July 7, 2011. The delivery service selected on the U.S.
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R mailed a notice of deficiency to Ps on Apr. 8, 2011. The 90th day after respondent mailed the notice of deficiency was Thursday, July 7, 2011, which was not a legal holiday in the District of Columbia. The petition was received by the Court and filed on July 12, 2011. The envelope in which the petition was received bears a Federal Express (FedEx) U.S. Airbill dated July 7, 2011. The delivery service selected on the U.S. Airbill is "Express Saver Third business day". Held: The petition was not timely filed, and the Court does not have jurisdiction to decide Ps' case.
1Opinion of the Court
MARCIUS J. SCAGGS AND ANDREA L. SCAGGS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Scaggs v. Comm'r
Docket No. 16342-11.
United States Tax Court
T.C. Memo 2012-258; 2012 Tax Ct. Memo LEXIS 257; 104 T.C.M. (CCH) 277;
September 10, 2012, Filed
An order dismissing this case for lack of jurisdiction because of an untimely filed petition will be entered.
R mailed a notice of deficiency to Ps on Apr. 8, 2011. The 90th day after respondent mailed the notice of deficiency was Thursday, July 7, 2011, which was not a legal holiday in the District of Columbia. The petition was received by the…
2Cases cited7 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Monge v. CommissionerUnited States Tax Court · 1989
- Woods v. CommissionerUnited States Tax Court · 1989
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- McCormick v. CommissionerUnited States Tax Court · 1970
2 more not listed; retrieve them via the Exa API.
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