Can a Taxpayer Prove Timely Filing of a Tax Court Petition If There Is No Postmark on the Envelope?
Michael J. Seely and Nancy P. Seely, Petitioners v. Commissioner of Internal Revenue, Respondent T.C. memo, 2020-6 | Filed January 13, 2020 If a taxpayer receives a statutory notice of deficiency (90-day letter) and wishes to petition the Tax Court, the taxpayer has 90 da... Steven R. Diamond, CPA
Is a Postmark made by Stamps.com Evidence of a Timely Filed Petition with the U.S. Tax Court?
Robert H. Tilden, Petitioner v. Commissioner of Internal Revenue, Respondent T.C. Memo. 2015-188 The jurisdiction of the U.S. Tax Court to redetermine a deficiency in income tax depends upon the issuance of a valid notice of deficiency and a timely filed petition by the taxpayer. The taxpayer normally has 90 days (150 days if the notice is addressed to a person outside the United States) to... Steven R. Diamond, CPA