Price v. Commissioner
United States Tax Court
Held, envelope containing petition, properly addressed to this Court in all respects, except that it contained an erroneous Washington, D.C., zip code number, is "properly addressed" for the purposes of sec. 301.7502-1(c)(1)(i), Proced. & Admin. Regs.
1Opinion of the Court
OPINION
Dawson, Judge:
This case was assigned to Special Trial Judge Randolph F. Caldwell, Jr., for hearing of respondent’s motion to dismiss for lack of jurisdiction. The Court agrees with and adopts his opinion, which is set forth below.1
OPINION OF THE SPECIAL TRIAL JUDGE
Caldwell, Special Trial Judge:
This case is presently before the Court on respondent’s motion to dismiss for lack of jurisdiction, filed September 22,1980. The issue presented by the motion is whether an erroneous zip code renders an otherwise correct address improper for purposes of sections 6213(a) and 7502. The motion came…
2Cases cited5 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Estate of Cerrito v. CommissionerUnited States Tax Court · 1980
- Minuto v. CommissionerUnited States Tax Court · 1976
- Hoffman v. CommissionerUnited States Tax Court · 1975
- Smetanka v. Comm'rUnited States Tax Court · 1980
3Cited by22 opinions
- Mollet v. CommissionerUnited States Tax Court · 1984
- Alfred P. Santoro, Claimant-Appellant v. Anthony J. Principi, Secretary of Veterans AffairsCourt of Appeals for the Federal Circuit · 2001
- Judkins v. Davenport, Texas Court of Appeals, 7th District (Amarillo)2000
- Hoffenberg v. CommissionerUnited States Tax Court · 1989
- Pickering v. CommissionerUnited States Tax Court · 1998
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