American Police & Fire Foundation, Inc. v. Commissioner
United States Tax Court
Respondent issued a notice of deficiency to petitioner corporation within 3 years after its dissolution. However, petitioner did not file its petition in this Court until after the termination of such 3-year period. Held, within the meaning of 18 Fla. Stat. Ann. sec. 607.297 an "action or proceeding" was begun at least with the issuance of a statutory notice.
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Respondent issued a notice of deficiency to petitioner corporation within 3 years after its dissolution. However, petitioner did not file its petition in this Court until after the termination of such 3-year period. Held, within the meaning of 18 Fla. Stat. Ann. sec. 607.297 an "action or proceeding" was begun at least with the issuance of a statutory notice. Accordingly, petitioner has the capacity to file a petition in this Court and respondent's motion to dismiss for lack of jurisdiction is denied.
1Opinion of the Court
AMERICAN POLICE AND FIRE FOUNDATION, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
American Police & Fire Foundation, Inc. v. Commissioner
Docket No. 22947-80.
United States Tax Court
T.C. Memo 1981-704; 1981 Tax Ct. Memo LEXIS 37; 43 T.C.M. (CCH) 77; T.C.M. (RIA) 81704;
December 14, 1981.
Respondent issued a notice of deficiency to petitioner corporation within 3 years after its dissolution. However, petitioner did not file its petition in this Court until after the termination of such 3-year period. Held, within the meaning of 18 Fla. Stat. Ann. sec. 607.297 an "action or…
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- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- United States v. Irwin FruchtmanCourt of Appeals for the Sixth Circuit · 1970
- Lawrence Rice and Walter Chipman v. United StatesCourt of Appeals for the Eighth Circuit · 1966
- National Committee to Secure Justice, etc. v. CommissionerUnited States Tax Court · 1957
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