Snow v. Comm'r
United States Tax Court
In 1993 R mailed notices of deficiency regarding Ps' 1987 and 1990 tax years. In 1995 Ps filed petitions with the Court. Ps moved to dismiss for lack of jurisdiction alleging that the notices of deficiency had not been mailed to Ps' last known address and were therefore invalid. R also moved to dismiss for lack of jurisdiction because the petitions were untimely. These cases were assigned to a Special Trial Judge who wrote an initial report granting Ps' motions to dismiss.
Read the full summary
In 1993 R mailed notices of deficiency regarding Ps' 1987 and 1990 tax years. In 1995 Ps filed petitions with the Court. Ps moved to dismiss for lack of jurisdiction alleging that the notices of deficiency had not been mailed to Ps' last known address and were therefore invalid. R also moved to dismiss for lack of jurisdiction because the petitions were untimely. These cases were assigned to a Special Trial Judge who wrote an initial report granting Ps' motions to dismiss. Because of the amounts in issue, the decisions in these cases were required by statute to be made by a regular Judge.…
1Opinion of the Court
DOUGLAS P. SNOW AND DEBORAH J. SNOW, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent;
DOUGLAS P. SNOW, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Snow v. Comm'r
Docket Nos. 6838-95, 6839-95
United States Tax Court
142 T.C. 413; 2014 U.S. Tax Ct. LEXIS 27; 142 T.C. No. 23;
June 17, 2014, Filed
Snow v. Commissioner, T.C. Memo 1996-457, 1996 Tax Ct. Memo LEXIS 478 (T.C., 1996)
Appropriate orders will be issued.
In 1993 R mailed notices of deficiency regarding Ps' 1987 and 1990 tax years. In 1995 Ps filed petitions with the Court. Ps moved to dismiss for lack of jurisdiction…
2Cases cited35 opinions
- United States v. DalmSupreme Court of the United States · 1990
- United States v. AcriSupreme Court of the United States · 1955
- Monge v. CommissionerUnited States Tax Court · 1989
- Commissioner v. McCoySupreme Court of the United States · 1987
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
30 more not listed; retrieve them via the Exa API.