Legal Opinion
Berger v. Commissioner
Court of Appeals for the Third Circuit
Decided November 29, 1968No. Nos. 17107-17109PublishedCited by 42 opinions
1Opinion of the Court
OPINION OF THE COURT
FREEDMAN, Circuit Judge.
These three petitions for review, which were consolidated for argument here as they were at the trial in the Tax Court, present two questions for consideration. One is whether the notices of income tax deficiency which the Commissioner sent to the taxpayers were directed to the statutory “last known address”, and the other is whether the notices were in any event effective because the taxpayers and their designated attorney admittedly received them in the regular course of the mail.
The problems presented grow out of § 6212 of the Internal Revenue…
2Cases cited22 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Phillips v. CommissionerSupreme Court of the United States · 1931
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
17 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Frieling v. CommissionerUnited States Tax Court · 1983
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Hoyle v. Comm'rUnited States Tax Court · 2008
- 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
37 more not listed; retrieve them via the Exa API.