« Today is Deadline for Submitting Comments to Panel on the Nonprofit Sector | Main | Germain Critiques Taxpayer's Reply Brief in Murphy »
March 30, 2007
What Can Brown Do For You? Can't Save Tax Court Petition Dropped Off at UPS on 91st Day
July 7: IRS mails notice of deficiency to Taxpayer- October 5 (last day to file petition in Tax Court): Taxpayer says he dropped petition off at local post office in the evening, but cannot produce a receipt
- October 6: Date typed on petition;
- October 6, 3:40 p.m.: Package received by UPS (per tracking record)
- October 10: Petition arrives at Tax Court via UPS
In Raczkowski v. Commissioner, T.C. Memo. 2007-72 (3/29/07), the Tax Court yesterday granted the IRS's motion to dismiss for lack of jurisdiction:
[T]he date on which an item is recorded electronically to the database of UPS is treated as the postmark date for purposes of section 7502.
March 30, 2007 in New Cases | Permalink
TrackBack
TrackBack URL for this entry:
http://www.typepad.com/services/trackback/6a00d8341c4eab53ef00d8342d19e553ef
Listed below are links to weblogs that reference What Can Brown Do For You? Can't Save Tax Court Petition Dropped Off at UPS on 91st Day:
» The Deadline Counts from Taxable Talk
Recently I assisted a client in preparing his paperwork to file a petition at the U.S. Tax Court. In my emails and letters to him, I emphasized,Make sure you mail the petition and accompanying docum... [Read More]
Tracked on Mar 30, 2007 7:24:44 PM
