Houghton v. Commissioner
United States Tax Court
On Mar. 19, 1966, respondent had on file in its Portland office a general power of attorney signed by petitioner, but not notarized or witnessed, appointing Warde H. Erwin as attorney-in-fact. The power of attorney requested that copies of all correspondence addressed to petitioner be sent to Erwin. On Apr. 4, 1966, requests for extensions of the statutory period of limitation on assessment were mailed to petitioner at his home address.
Read the full summary
On Mar. 19, 1966, respondent had on file in its Portland office a general power of attorney signed by petitioner, but not notarized or witnessed, appointing Warde H. Erwin as attorney-in-fact. The power of attorney requested that copies of all correspondence addressed to petitioner be sent to Erwin. On Apr. 4, 1966, requests for extensions of the statutory period of limitation on assessment were mailed to petitioner at his home address. These were turned over to his attorney who discussed them with respondent's agent. On June 8, 1966, respondent sent by certified mail to petitioner at his…
1Opinion of the Court
Dawson, Judge:
On February 10, 1967, respondent filed a motion to dismiss the petition in this proceeding for lack of jurisdiction because it was not filed within 90 days after the mailing of the notice of deficiency, as provided by section 6213(a), I.R.C. 1954.1 On February 17,1967, the Court entered an order stating that the case would be dismissed unless the petitioner filed written objections to respondent’s motion. On March 6, 1967, the petitioner filed his objections to the motion together with certain pertinent exhibits. Pursuant to the Court’s order, a hearing on the motion was held in…
2Cases cited20 opinions
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Moffat v. CommissionerUnited States Tax Court · 1966
- Roy W. Dewelles v. United States of AmericaCourt of Appeals for the Ninth Circuit · 1967
- Lester L. Luhring and Betty W. Luhring v. Clifford W. Glotzbach, District Director of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
- Brzezinski v. CommissionerUnited States Tax Court · 1954
15 more not listed; retrieve them via the Exa API.
3Cited by49 opinions
- Pyo v. CommissionerUnited States Tax Court · 1984
- Lifter v. CommissionerUnited States Tax Court · 1973
- Cataldo v. CommissionerUnited States Tax Court · 1973
- Keeton v. CommissionerUnited States Tax Court · 1980
- Estate of McKaig v. CommissionerUnited States Tax Court · 1968
44 more not listed; retrieve them via the Exa API.