Legal Opinion
David Deutsch v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 30, 1979No. 804, Docket 79-4004PublishedCited by 70 opinions
1Opinion of the Court
PIERCE, District Judge:
This is an appeal from the dismissal of a petition to the United States Tax Court on the ground that the petition was untimely filed.
On June 29, 1977, the Internal Revenue Service issued a notice of deficiency to the taxpayer David Deutsch for a total of $27,006.68. On October 12, 1977, 105 days after issuance of the notice, the Tax Court received and filed as a petition a copy of a letter dated August 4,1977 and postmarked “Oct. [illigible] 1977.” This letter was signed by the taxpayer’s accountant, 1 and although addressed to the Internal Revenue Service office in Los…
2Cases cited6 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Irving and Helen Fishman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- George K. Drake and Charlene C. Drake v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1977
- Thomas and Delilah Boccuto v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
1 more not listed; retrieve them via the Exa API.
3Cited by70 opinions
- Lois Anderson v. United StatesCourt of Appeals for the Ninth Circuit · 1992
- Estate of Leonard A. Wood, Deceased, J.M. Loonan, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
- Brian Miller v. United StatesCourt of Appeals for the Sixth Circuit · 1986
- Philadelphia Marine Trade Ass'n-International Longshoremen's Ass'n Pension Fund v. CommissionerCourt of Appeals for the Third Circuit · 2008
- Sorrentino v. Internal Revenue ServiceCourt of Appeals for the Tenth Circuit · 2004
65 more not listed; retrieve them via the Exa API.