Bunnel v. Commissioner
United States Tax Court
Petitioners and their wholly owned corporation, which had in effect an election under subchap. S of the Code during 2 of the 3 years in issue, were in the business of dealing in oil leases. Respondent's notices of deficiencies for the 2 years in which the election was in effect were based in part on adjustments to the income of the corporation. Held, the notices of deficiency were valid notwithstanding the fact that such notices were not mailed to the corporation.
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Petitioners and their wholly owned corporation, which had in effect an election under subchap. S of the Code during 2 of the 3 years in issue, were in the business of dealing in oil leases. Respondent's notices of deficiencies for the 2 years in which the election was in effect were based in part on adjustments to the income of the corporation. Held, the notices of deficiency were valid notwithstanding the fact that such notices were not mailed to the corporation. Held, further, that the oil leases which petitioners and the corporation sold were property held for the sale to customers in the…
1Opinion of the Court
Tannenwald, Judge:
Respondent determined (a) deficiencies in petitioner Robert L. Bunnel’s 1958 income tax in the amount of $1,267.81 and an addition to tax in the amount of $63.37 and (b) deficiencies in petitioners Robert L. Bunnel and Vola V. Bunnel’s 1960 and 1961 income tax in the amounts of $24,695.10 and $10,804.89, respectively, and additions to tax in the amounts of $1,234.76 and $540.24, respectively. The cases were consolidated for trial. After concessions by both petitioners and respondent, three issues remain for disposition: First, whether the mailing to a corporation, which has…
2Cases cited10 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Courtney v. CommissionerUnited States Tax Court · 1957
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
- Perlmutter v. CommissionerUnited States Tax Court · 1965
- Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
5 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Fehlhaber v. CommissionerUnited States Tax Court · 1990
- Warrensburg Bd. & Paper Corp. v. CommissionerUnited States Tax Court · 1981
- Chaum v. CommissionerUnited States Tax Court · 1977
- Sam Goldberger, Inc. v. CommissionerUnited States Tax Court · 1987
- Alfieri v. CommissionerUnited States Tax Court · 1973
34 more not listed; retrieve them via the Exa API.