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So You Think You Can Trust Certified Mail?
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BobKamman
Level 15
11-28-2022
01:29 PM
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From a Tax Court order today:
On February 24, 2022, the Court received and filed a petition from petitioner. However, upon review of the Notice of Deficiency included in petitioner's petition, filed on February 24, 2022, it was seen that the last date for petitioners to file a petition with the Court was February 22, 2022. The envelope that the petition was sent in does not appear to bear a legible postmark of the date sent and checking the certified mail tracking number on the envelope only provides the tracking history from when it arrived at the Washington D.C. Post office, not the date it was mailed. Therefore, it appears that the petition was not timely filed with the Court.
Upon due consideration, it is hereby
ORDERED that, on or before December 28, 2022, the parties shall show cause
in writing as to why the Court, on its own motion, should not dismiss this case for Lack of Jurisdiction upon the ground that the petition in this case was not filed within the time prescribed by I.R.C. § 6330 or § 7502.
Note: The taxpayer lives in Hawaii.
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