Legal Opinion
Eve C.W. Wallin v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 28, 1984No. 83-7244PublishedCited by 55 opinions
1Opinion of the Court
PREGERSON, Circuit Judge:
The Tax Court dismissed Eve C.W. Wallin’s (Wallin’s) petition for redetermination of tax deficiency as untimely. The Internal Revenue Service (IRS) sent a notice of tax deficiency to Wallin’s former address although it had notice that Wallin had moved. Wallin did not receive the deficiency notice within the time limit allowed to file a petition for redetermination. The Tax Court ruled that the IRS exercised reasonable diligence in searching for Wallin’s new address and that sending the deficiency notice to Wallin’s- former address was sufficient. We reverse.
I. FACTS
Wal…
2Cases cited9 opinions
- Adickes v. S. H. Kress & Co.Supreme Court of the United States · 1970
- Wood v. Santa Barbara Chamber of Commerce, Inc.Court of Appeals for the Ninth Circuit · 1983
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
4 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Theede v. United States Department of LaborCourt of Appeals for the Tenth Circuit · 1999
- Pyo v. CommissionerUnited States Tax Court · 1984
- Joseph F. Purcell, Plaintiff-Counter-Claim-Defendant-Appellant v. United States of America, Defendant-Counter-Claimant-AppelleeCourt of Appeals for the Ninth Circuit · 1993
- 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
50 more not listed; retrieve them via the Exa API.