Legal Opinion
Royal E. Jorgensen and Mary M. Jorgensen v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided July 5, 1957No. 15356_1PublishedCited by 5 opinions
1Per curiam
This case, here on appeal from the Tax Court, involves a deficiency in federal income taxes determined by the Commissioner for the calendar year 1952,
On October 20, 1955, the Commissioner, by registered mail, sent to the taxpayers (petitioners here) a notice of deficiency. On January 23, 1956, the taxpayers filed a petition with the Tax Court for a redetermination. That court dismissed the petition as untimely filed.
It appears that the postmark stamped on the envelope containing the petition was dated January 20, 1956, which was the 92nd day after the notice of deficiency had been mailed.…
2Cases cited1 opinion
- Di Prospero v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
3Cited by5 opinions
- James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Bernard Bloch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Edward J. Healy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1965
- Tomie Kennedy v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1964
- Heaberlin v. CommissionerUnited States Tax Court · 1960