Legal Opinion

Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico v. Commissioner of Internal Revenue

Court of Appeals for the Eleventh Circuit

Decided January 2, 1985No. 84-8316, 84-8318PublishedCited by 44 opinions

Non-Argument Calendar.

1Per curiam

These two appeals arise from the tax court’s dismissal of the taxpayers’ petitions for redetermination of income tax deficiencies. We affirm the dismissals for lack of jurisdiction because the petitions were filed after the expiration of the 90-day period permitted for filing such petitions.

The facts in each case are undisputed. On October 4, 1983, the Commissioner of Internal Revenue sent to appellant Pugsley a statutory notice of deficiency in income tax. This notice was addressed to Pugsley at a Tampa, Florida address, and was immediately forwarded to Pugsley at his current address in St.…

2Cases cited7 opinions

  1. Frieling v. CommissionerUnited States Tax Court · 1983
  2. Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
  3. Looper v. CommissionerUnited States Tax Court · 1980
  4. Mulvania v. CommissionerUnited States Tax Court · 1983
  5. Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957

2 more not listed; retrieve them via the Exa API.

3Cited by44 opinions

  1. Castillo, Ex Parte Mario AmaroCourt of Criminal Appeals of Texas · 2012
  2. Cyclone Drilling, Inc., a Wyoming Corporation v. Michael J. Kelley, as District Director of Internal Revenue Service for the Cheyenne DistrictCourt of Appeals for the Tenth Circuit · 1985
  3. Patmon and Young Professional Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1995
  4. Edward M. Sanders v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
  5. Terrell v. CommissionerCourt of Appeals for the Fifth Circuit · 2010

39 more not listed; retrieve them via the Exa API.

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