Legal Opinion

John D. Borgman v. Commissioner of Internal Revenue

Court of Appeals for the First Circuit

Decided November 17, 1989No. 89-1317PublishedCited by 13 opinions

1Opinion of the Court

MAYER, Circuit Judge.

This is an appeal from an order of the United States Tax Court denying John Borgman’s motion for summary judgment on his petition for a redetermination of income tax deficiencies. The court held that the Commissioner’s notice of deficiency was valid and timely even though it was not mailed to Borgman’s last known address. Borgman v. Commissioner, 48 T.C.M. (CCH) 1180 (1984). Following the denial of summary judgment, the parties stipulated the fact and the amount of the deficiencies, and an order and decision was entered upon their joint motion, preserving the summary…

2Cases cited5 opinions

  1. Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
  2. Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
  3. Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
  4. Richard L. Mulvania v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
  5. Borgman v. CommissionerUnited States Tax Court · 1984

3Cited by13 opinions

  1. Smith v. CommissionerUnited States Tax Court · 2000
  2. Christopher Gyorgy v. CIRCourt of Appeals for the Seventh Circuit · 2015
  3. Patmon and Young Professional Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1995
  4. Terrell v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
  5. Boritz v. United StatesDistrict Court, District of Columbia · 2010

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