Grimm v. Comm'r
United States Tax Court
R mailed P a notice of determination sustaining a proposed collection action. P prepared a petition, applied postage using a private postage meter, and mailed the petition to the Court. The Court did not receive the petition within 30 days of the date of the notice of determination. Further, the petition was received by the Court later than a document "would ordinarily be received if it were postmarked at the same point of origin by the U.S.
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R mailed P a notice of determination sustaining a proposed collection action. P prepared a petition, applied postage using a private postage meter, and mailed the petition to the Court. The Court did not receive the petition within 30 days of the date of the notice of determination. Further, the petition was received by the Court later than a document "would ordinarily be received if it were postmarked at the same point of origin by the U.S. Postal Service on the * * * last day of the period, prescribed for filing the * * * [petition]." R moved to dismiss the case for lack of jurisdiction.…
1Opinion of the Court
DALE GRIMM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Grimm v. Comm'r
Docket No. 4649-16L.
United States Tax Court
T.C. Memo 2017-44; 2017 Tax Ct. Memo LEXIS 44; 113 T.C.M. (CCH) 1197;
March 16, 2017, Filed
An appropriate order will be entered granting respondent's motion to dismiss for lack of jurisdiction.
R mailed P a notice of determination sustaining a proposed collection action. P prepared a petition, applied postage using a private postage meter, and mailed the petition to the Court. The Court did not receive the petition within 30 days of the date of the notice of…
2Cases cited3 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Weber v. Comm'rUnited States Tax Court · 2004
- Dees v. Comm'rUnited States Tax Court · 2017