Legal Opinion
Repetti v. Jamison
District Court, N.D. California
Decided February 2, 1955No. 33161PublishedCited by 16 opinions
1Opinion of the Court
OLIVER J. CARTER, District Judge.
Plaintiff instituted this action under 26 U.S.C.A. § 272(a) (1) to restrain the assessment of income taxes claimed by defendant to be due to the Government. The section under which plaintiff proceeds provides as follows:
“If in the case of any taxpayer, the Commissioner determines that there is a deficiency in respect of the tax imposed by this chapter, the Commissioner is authorized to send notice of such deficiency to the taxpayer by registered mail. Within ninety days after such notice is mailed * * '* the taxpayer may file a petition with the Board of Tax…
2Cases cited5 opinions
- Ventura Consolidated Oil Fields v. RoganCourt of Appeals for the Ninth Circuit · 1936
- Moore v. Cleveland Ry. Co.Court of Appeals for the Sixth Circuit · 1940
- Maxwell v. Campbell, Collector of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Moir v. CommissionerUnited States Board of Tax Appeals · 1925
- Hastings & Co. v. SmithDistrict Court, E.D. Pennsylvania · 1954
3Cited by16 opinions
- F.B. Blansett and Ethel Blansett v. United StatesCourt of Appeals for the Eighth Circuit · 1960
- Huffman v. Comm'rUnited States Tax Court · 2006
- Glen T. Jamison, Director of Internal Revenue v. Maria RepettiCourt of Appeals for the Ninth Circuit · 1956
- Capital One Fin. Corp. v. Comm'rUnited States Tax Court · 2008
- Kearney v. A'HearnDistrict Court, S.D. New York · 1962
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