Legal Opinion
Jeffrey D. Gregory v. Commissioner
United States Tax Court
Decided November 20, 2018No. 1090-16LUnpublished
1Opinion of the Court
T.C. Memo. 2018-192
UNITED STATES TAX COURT JEFFREY D. GREGORY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 1090-16L. Filed November 20, 2018. R filed a notice of Federal tax lien to secure the collection of an unpaid liability shown on P's Federal income tax return for 2005 and a deficiency R determined for 2009. P does not dispute his liability for 2005 but challenges the validity of R's assessment of a deficiency for 2009 because of an alleged failure to mail him a notice of deficiency. Held: A "reprint" of a notice of deficiency for P's 2009 taxable year evidences…
2Cases cited8 opinions
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
- Rochelle v. CommissionerCourt of Appeals for the Fifth Circuit · 2002
- Virgil B. Elings v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 2003
- Muncy v. Comm'rUnited States Tax Court · 2017
- Weiss v. Comm'rUnited States Tax Court · 2016
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