Berger v. Commissioner
United States Tax Court
The petitioners filed tax returns, protests, and powers of attorney with the respondent designating specific addresses as their own. The powers of attorney directed that correspondence addressed to the taxpayer concerning income tax matters for the years in question should be sent to petitioners' attorney.
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The petitioners filed tax returns, protests, and powers of attorney with the respondent designating specific addresses as their own. The powers of attorney directed that correspondence addressed to the taxpayer concerning income tax matters for the years in question should be sent to petitioners' attorney. Deficiency notices were sent by registered mail to the petitioners at the addresses given in the returns; protests and powers and copies of the notices were sent by ordinary mail to petitioners' attorney. The notices and copies were received by the proper parties in ample time to file a…
1Opinion of the Court
OPINION
Tietjens, Judge:
These consolidated proceedings involve income tax deficiencies and addition to tax as follows:
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The sole issue is whether the Commissioner validly issued notices of deficiency to the petitioners in accordance with section 6212 of the Internal Revenue Code of 1954.2
All of the facts are stipulated, and are so found. The stipulations and exhibits thereto are incorporated herein by this reference.
Milton Berger (hereinafter sometimes referred to as Berger) and Ruth K. Berger filed their income tax returns for the taxable years 1960, 1961, and 1962 with the…
2Cases cited6 opinions
- Dolezilek v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1954
- A. Ralph D'AnDreA v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1959
- Birnie v. CommissionerUnited States Tax Court · 1951
- Marvin v. CommissionerUnited States Tax Court · 1963
- Parker v. CommissionerUnited States Tax Court · 1949
1 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Frieling v. CommissionerUnited States Tax Court · 1983
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Hoyle v. Comm'rUnited States Tax Court · 2008
- Lifter v. CommissionerUnited States Tax Court · 1973
- Mulvania v. CommissionerUnited States Tax Court · 1983
37 more not listed; retrieve them via the Exa API.