Delman v. Commissioner
United States Tax Court
Respondent mailed a notice of deficiency to the petitioners in care of their accountant, the address petitioners used on their 1961 return. Held: The purpose of sec. 6212, I.R.C. 1954, is to establish a procedure which results in a high probability that taxpayers will receive notice of any deficiency. Under all the facts and circumstances, respondent acted reasonably, and petitioners had an adequate opportunity to file a timely petition.
1Opinion of the Court
Joseph Delman and Jeanette Delman v. Commissioner.
Delman v. Commissioner
Docket No. 1844-65.
United States Tax Court
T.C. Memo 1966-59; 1966 Tax Ct. Memo LEXIS 220; 25 T.C.M. (CCH) 328; T.C.M. (RIA) 66059;
March 22, 1966
Respondent mailed a notice of deficiency to the petitioners in care of their accountant, the address petitioners used on their 1961 return. Held: The purpose of sec. 6212, I.R.C. 1954, is to establish a procedure which results in a high probability that taxpayers will receive notice of any deficiency. Under all the facts and circumstances, respondent acted reasonably, and…
2Cases cited9 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Brzezinski v. CommissionerUnited States Tax Court · 1954
- Heaberlin v. CommissionerUnited States Tax Court · 1960
- 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
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