Legal Opinion
Anthony Teong-Chan Gaw Rossana W. Gaw v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided January 31, 1995No. 93-1619PublishedCited by 18 opinions
1Opinion of the Court
Opinion for the Court filed by Circuit Judge TATEL.
TATEL, Circuit Judge:
Anthony and Rossana Gaw appeal the Tax Court’s dismissal of their petition for a rede-termination of an Internal Revenue Service notice of deficiency on the ground that the petition was not timely filed. Because we find that the Gaws’ receipt of the notice was delayed as a result of the IRS’s failure to exercise reasonable diligence in complying with the “last known address” rule, we conclude that the Gaws’ petition was timely filed. We therefore reverse and remand to the Tax Court for its consideration of the merits of…
2Cases cited10 opinions
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Abeles v. CommissionerUnited States Tax Court · 1988
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- William J. Crum v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1980
- Harold J. Marks, A/K/A Haley Justin Van De Mark and Lea Marks, A/K/A Alanna Leigh Van De Mark v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1991
5 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Drew v. Department of CorrectionsCourt of Appeals for the Eleventh Circuit · 2002
- Christopher Gyorgy v. CIRCourt of Appeals for the Seventh Circuit · 2015
- Terrell v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
- Pollock v. Comm'rUnited States Tax Court · 2009
- Warren Richard Follum v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1997
13 more not listed; retrieve them via the Exa API.