Quarterman v. Comm'r
United States Tax Court
P mailed his petition using the registered airmail service of a foreign country on Sept. 27, 2010, the 145th day after the mailing of a notice of deficiency to an address in the foreign country where P resides. The envelope in which the petition was mailed to the Court, which did not bear a postmark made by the U.S. Postal Service, entered the domestic mail service of the United States no later than Oct. 4, 2010, the last day of the filing period.
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P mailed his petition using the registered airmail service of a foreign country on Sept. 27, 2010, the 145th day after the mailing of a notice of deficiency to an address in the foreign country where P resides. The envelope in which the petition was mailed to the Court, which did not bear a postmark made by the U.S. Postal Service, entered the domestic mail service of the United States no later than Oct. 4, 2010, the last day of the filing period. The petition was received by the Court early the next morning. Held: The petition was timely filed, and the Court has jurisdiction to hear P's case.
1Opinion of the Court
WILLIAM J. QUARTERMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Quarterman v. Comm'r
Docket No. 22007-10.
United States Tax Court
T.C. Memo 2011-258; 2011 Tax Ct. Memo LEXIS 248; 102 T.C.M. (CCH) 437;
November 1, 2011, Filed
An order will be issued granting petitioner's motion to vacate, as supplemented.
P mailed his petition using the registered airmail service of a foreign country on Sept. 27, 2010, the 145th day after the mailing of a notice of deficiency to an address in the foreign country where P resides. The envelope in which the petition was mailed to the Court, which did…
2Cases cited6 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Monge v. CommissionerUnited States Tax Court · 1989
- Normac, Inc. v. CommissionerUnited States Tax Court · 1988
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Mason v. CommissionerUnited States Tax Court · 1977
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