Legal Opinion

Dudley v. Comm'r

United States Tax Court

Decided August 14, 1957No. Docket No. 66978PublishedCited by 14 opinions

Jurisdiction -- Notice of Deficiency -- Department of Finance of Virgin Islands. -- There is no showing that the Head of the Tax Division of the Department of Finance of the Government of the Virgin Islands was authorized as a delegate of the Secretary under section 6212 of the I. R. C. 1954 to notify the petitioner of a deficiency in income tax and a notice from such person does not give this Court jurisdiction.

1Opinion of the Court

OPINION.

Murdock, Judge:

The Commissioner has moved to dismiss this case for lack of jurisdiction. The parties were heard on that motion.

The petitioner and his wife received a letter dated October 26,1956, from the Head of the Tax Division of the Department of Finance of the “Government of the Virgin Islands of the United States” advising that $6,567.31 was due on their income tax for the year 1955. The petitioner and his wife also received a letter dated February 15, 1957, referring to the letter of October 26, 1956, and advising that unless a petition was filed “with the Court” for review or…

2Cases cited1 opinion

  1. Fairchild v. CommissionerUnited States Tax Court · 1955

3Cited by14 opinions

  1. Perlmutter v. CommissionerUnited States Tax Court · 1965
  2. George H. T. Dudley v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
  3. Stamos v. CommissionerUnited States Tax Court · 1990
  4. Chicago Bridge and Iron Company, Ltd. v. Ruben B. Wheatley, Commissioner of FinanceCourt of Appeals for the Third Circuit · 1970
  5. Knapp v. CommissionerUnited States Tax Court · 1988

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