Blum v. Commissioner
United States Tax Court
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
OPINION
STERRETT, Chief Judge:
Respondent’s motion to dismiss for lack of jurisdiction filed herein was assigned to Special Trial Judge Francis J. Cantrel pursuant to section 7456(d)(4), Internal Revenue Code of 1954 as amended, and Rule 180, Tax Court Rules of Practice and Procedure. After a review of the record, we agree with and adopt his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
CANTREL, Special Trial Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction filed on August 15, 1985. Respondent seeks dismissal on the ground that…
2Cases cited10 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Harold Patz Trust v. CommissionerUnited States Tax Court · 1977
- George K. Drake and Charlene C. Drake v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1977
- Estate of Cerrito v. CommissionerUnited States Tax Court · 1980
5 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- Hawkins v. Comm'rUnited States Tax Court · 2003
- Manchester Group v. CommissionerUnited States Tax Court · 1994
- Alpha Chem. Partners v. CommissionerUnited States Tax Court · 1995
- Blum v. CommissionerUnited States Tax Court · 1986