McCue v. Commissioner
United States Tax Court
Jurisdiction -- Second Notice. -- Where the Commissioner mails a valid notice and a petition is filed with this Court pursuant thereto, he has no authority, at any time after mailing the first notice, to send a second notice to the same addressee relating to the same tax liability.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner mailed a notice to Agnes McCue on September 28, 1942, in which he stated that she was liable as a transferee for estate tax liability of the estate of John J. Nolan in the amount of $55,346.49. Agnes McCue filed a petition with this Court within 90 days of the receipt of that letter, contesting her liability as determined therein by the Commissioner. That is the proceeding at Docket No. 233. However, before she filed that petition, the Commissioner sent her another letter dated November 2, 1942, advising her of his determination that she was liable as a…
2Cited by32 opinions
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
- Stamm International Corp. v. CommissionerUnited States Tax Court · 1985
- Richardson v. CommissionerUnited States Tax Court · 1981
- American Found. Co. v. CommissionerUnited States Tax Court · 1943
- Barth Foundation v. CommissionerUnited States Tax Court · 1981
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