Gray v. Commissioner
United States Tax Court
Held: 1. An attorney admitted to practice before this Court who files a petition in the name of a taxpayer to whom a notice of deficiency is addressed is presumed to have the authority to do so, and if respondent challenges that authority, it is incumbent on him to prove a lack of such authority; 2. Under Rule 60(a), Tax Court Rules of Practice and Procedure, a case timely brought in the name of a petitioner to whom a notice of deficiency is addressed will not be dismissed…
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Held: 1. An attorney admitted to practice before this Court who files a petition in the name of a taxpayer to whom a notice of deficiency is addressed is presumed to have the authority to do so, and if respondent challenges that authority, it is incumbent on him to prove a lack of such authority; 2. Under Rule 60(a), Tax Court Rules of Practice and Procedure, a case timely brought in the name of a petitioner to whom a notice of deficiency is addressed will not be dismissed when the petitioner ratifies the filing of the petition promptly upon objection; 3. A notice of deficiency timely mailed…
1Opinion of the Court
Shirley Gray, Petitioner v. Commissioner of Internal Revenue, Respondent
Gray v. Commissioner
Docket No. 6483-79
United States Tax Court
73 T.C. 639; 1980 U.S. Tax Ct. LEXIS 207;
January 7, 1980, Filed
Held: 1. An attorney admitted to practice before this Court who files a petition in the name of a taxpayer to whom a notice of deficiency is addressed is presumed to have the authority to do so, and if respondent challenges that authority, it is incumbent on him to prove a lack of such authority;
2. Under Rule 60(a), Tax Court Rules of Practice and Procedure, a case timely brought in the name of a…
2Cases cited16 opinions
- Osborn v. Bank of United StatesSupreme Court of the United States · 1824
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Lifter v. CommissionerUnited States Tax Court · 1973
- Booth v. FletcherCourt of Appeals for the D.C. Circuit · 1938
- McCormick v. CommissionerUnited States Tax Court · 1970
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