In Uncategorized on 04/20/2020 at 14:54

To Jorge Castillo, Docket No. 19507-19, filed 4/20/20, who asserts entitlement to relief from the 90 day bar to his petition from a SNOD per Section 7508(a)(1)(c) because he was situated as above set forth on the magic ninetieth day, I can only respond “as you were then, so was I once.”

But though Ch J Maurice B (“Mighty Mo”) Foley is sympathetic, he rules that boot camp in South Carolina is not sufficiently a combat zone or a contingency operation to warrant statutory relief.

“I.R.C. section 7508(a)(1)(C) extends the time to file a Tax Court petition with respect to a notice of deficiency if an individual is in military service in a combat zone or contingency operation. Nothing that petitioner submitted has established that I.R.C. section 7508(a)(1)(C) is applicable to this particular case.” Order, at p. 2.

Judge, there were times I couldn’t tell the difference. I bet Jorge feels the same way. Jorge, good luck, man.


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