Legal Opinion
William I. Tenzer v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided December 30, 1960No. 16513_1PublishedCited by 49 opinions
1Opinion of the Court
CHAMBERS, Circuit Judge.
Tenzer contends that he has a right to-litigate in the Tax Court a deficiency determination on his 1952 federal income-taxes because he filed there a petition for review within 90 days1 after personal service 2 upon him of a copy of the Commissioner’s notice which was adverse to-him. This notice is commonly called the 90-day letter. But the Commissioner-says, “No.” He relies on the fact that-the collector, 28 days before the personal service, had placed in the mail3 the same-notice addressed to Tenzer at his correct address in Los Angeles.4 The Commissioner counts the…
2Cases cited5 opinions
- Clifford O. Boren v. R. A. Riddell, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Bernard Bloch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Dolezilek v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1954
- Eppler v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
- Rosewood Hotel, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
3Cited by49 opinions
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Frieling v. CommissionerUnited States Tax Court · 1983
- Pyo v. CommissionerUnited States Tax Court · 1984
- 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
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