Legal Opinion

Blum v. Commissioner

United States Tax Court

Decided May 29, 1986No. Docket No. 22853-85Published

On the 90th day after the notice of deficiency was mailed, P delivered her petition to a private delivery service and contracted for express delivery of the original petition and electronic transmission of a copy of the petition via satellite to be delivered that same day.

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On the 90th day after the notice of deficiency was mailed, P delivered her petition to a private delivery service and contracted for express delivery of the original petition and electronic transmission of a copy of the petition via satellite to be delivered that same day. Pursuant to the terms of delivery, a copy of the petition was electronically reprinted in Washington, D.C., and was tendered to the Court by the private delivery service that same day; however, the Court refused to receive the electronically transmitted copy. The original petition was hand-delivered to the Court and filed…

1Opinion of the Court

Lois Blum, Petitioner v. Commissioner of Internal Revenue, Respondent

Blum v. Commissioner

Docket No. 22853-85

United States Tax Court

86 T.C. 1128; 1986 U.S. Tax Ct. LEXIS 101; 86 T.C. No. 65;

May 29, 1986, Filed

An appropriate order of dismissal for lack of jurisdiction will be entered.

On the 90th day after the notice of deficiency was mailed, P delivered her petition to a private delivery service and contracted for express delivery of the original petition and electronic transmission of a copy of the petition via satellite to be delivered that same day. Pursuant to the terms of delivery, a copy…

2Cases cited11 opinions

  1. Moffat v. CommissionerUnited States Tax Court · 1966
  2. Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
  3. Harold Patz Trust v. CommissionerUnited States Tax Court · 1977
  4. George K. Drake and Charlene C. Drake v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1977
  5. Estate of Cerrito v. CommissionerUnited States Tax Court · 1980

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