Legal Opinion
Simon v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 27, 1949No. 196, Docket 20962PublishedCited by 34 opinions
1Opinion of the Court
FRANK, Circuit Judge.
1. Jurisdiction:
As we understand it, taxpayer and the government agree as follows: (a) If the Tax Court, on April 28, 1947, when the taxpayer filed his motion for reconsideration, still had statutory power to act with respect to the proceedings, then, under 26 U.S.C.A. § 1142, the time, three months, for filing a petition for review in this court of the Tax Court’s decision began to run from the time of the Tax Court’s denial of the motion on April 29, 1947, and the petition for review, filed July 24, 1947, was timely, (b) The statutory power of the Tax Court to act…
2Cases cited2 opinions
- Union National Bank v. LambSupreme Court of the United States · 1949
- Denholm & McKay Co. v. Commissioner of Int. Rev.Court of Appeals for the First Circuit · 1942
3Cited by34 opinions
- United Mine Workers of America, International Union v. Elizabeth H. Dole, in Her Capacity as Secretary of Labor, American Mining Congress, IntervenorCourt of Appeals for the D.C. Circuit · 1989
- Stewart v. Comm'rUnited States Tax Court · 2006
- United States v. BalanovskiCourt of Appeals for the Second Circuit · 1956
- William G. Nordvik Claire N. Nordvik v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Tigers Eye Trading, LLC v. Comm'rUnited States Tax Court · 2012
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