Legal Opinion

Hollister v. Commissioner

United States Tax Court

Decided January 24, 1979No. Docket Nos. 6674-78, 6675-78, 6676-78Unpublished

Petitioners received properly addressed notices of deficiency 3 days after they were mailed. Petitions were received and filed by the Tax Court on the 94th day after they were mailed to the taxpayers in envelopes bearing legible U.S. postmarks dated the 91st day after notices of deficiency were mailed. Held, under the circumstances the petitions were not timely filed and respondent's motion to dismiss must be granted.

1Opinion of the Court

SIDNEY J. HOLLISTER and ROBERTA C. HOLLISTER, 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hollister v. Commissioner

Docket Nos. 6674-78, 6675-78, 6676-78.

United States Tax Court

T.C. Memo 1979-35; 1979 Tax Ct. Memo LEXIS 493; 38 T.C.M. (CCH) 139; T.C.M. (RIA) 79035;

January 24, 1979, Filed

Petitioners received properly addressed notices of deficiency 3 days after they were mailed. Petitions were received and filed by the Tax Court on the 94th day after they were mailed to the taxpayers in envelopes bearing legible U.S. postmarks dated the 91st day after notices of deficiency were…

2Cases cited16 opinions

  1. Moffat v. CommissionerUnited States Tax Court · 1966
  2. Sylvan v. CommissionerUnited States Tax Court · 1975
  3. James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
  4. Estate of McKaig v. CommissionerUnited States Tax Court · 1968
  5. William I. Tenzer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960

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