Brown v. Commissioner
United States Tax Court
During the course of an examination, petitioners requested respondent to direct all future correspondence to them to an APO address in New York. Respondent subsequently sent petitioners a notice of deficiency addressed to them at the APO address. Petitioners filed a petition 145 days after the notice was sent. Respondent filed a motion to dismiss for lack of jurisdiction more than 45 days after the petition was served.
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During the course of an examination, petitioners requested respondent to direct all future correspondence to them to an APO address in New York. Respondent subsequently sent petitioners a notice of deficiency addressed to them at the APO address. Petitioners filed a petition 145 days after the notice was sent. Respondent filed a motion to dismiss for lack of jurisdiction more than 45 days after the petition was served. Held, this Court's jurisdiction can be questioned by either party, or by the Court sua sponte, at any time. Held, further, the notice was addressed to petitioners at their…
1Opinion of the Court
Henry M. Brown and Barbara J. Brown, Petitioners v. Commissioner of Internal Revenue, Respondent
Brown v. Commissioner
Docket No. 12481-81
United States Tax Court
78 T.C. 215; 1982 U.S. Tax Ct. LEXIS 139; 78 T.C. No. 15;
February 8, 1982, Filed
During the course of an examination, petitioners requested respondent to direct all future correspondence to them to an APO address in New York. Respondent subsequently sent petitioners a notice of deficiency addressed to them at the APO address. Petitioners filed a petition 145 days after the notice was sent. Respondent filed a motion to dismiss for lack of…
2Cases cited16 opinions
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Lifter v. CommissionerUnited States Tax Court · 1973
- McCormick v. CommissionerUnited States Tax Court · 1970
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
- Looper v. CommissionerUnited States Tax Court · 1980
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