Reddock v. Commissioner
United States Tax Court
On Apr. 12, 1978, respondent mailed a notice of deficiency for 1974 to petitioners at an incorrect address, and the notice was returned to the Internal Revenue Service. On Apr. 26, 1978, more than 3 years after petitioners' income tax return for 1974 was filed, respondent mailed the notice to petitioners at another address.
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On Apr. 12, 1978, respondent mailed a notice of deficiency for 1974 to petitioners at an incorrect address, and the notice was returned to the Internal Revenue Service. On Apr. 26, 1978, more than 3 years after petitioners' income tax return for 1974 was filed, respondent mailed the notice to petitioners at another address. Petitioners filed their petition in this Court on July 11, 1978. Held, assessment of a deficiency in petitioners' income tax for 1974 is barred by the 3-year statute of limitations prescribed by sec. 6501(a), I.R.C. 1954.
1Opinion of the Court
OPINION
Featherston, Judge:
This case involves a deficiency in the amount of $20,184 in petitioners’ Federal income tax for 1974 together with an addition to such tax in the amount of $1,009 under section 6653(a).1 Petitioners have filed a motion to reconsider an order of this Court, dated November 22, 1978, denying their motion to strike, to dismiss, and to enjoin. The motion which was denied requested the Court (a) to strike paragraph 9(a) of respondent’s answer, (b) to dismiss the answer on the ground that the statute of limitations bars the assessment, (c) to dismiss the answer for lack of…
2Cases cited16 opinions
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Lifter v. CommissionerUnited States Tax Court · 1973
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Robinson v. CommissionerUnited States Tax Court · 1972
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