Shelton v. Commissioner
United States Tax Court
The notice of deficiency was not mailed to petitioners at their last known address and petitioners did not receive the notice in time to file a timely petition in this Court. Upon receiving a notice of collection of the deficiency for the years involved, petitioners obtained a copy of the notice of deficiency and filed an untimely petition in this Court. Respondent moved to dismiss for lack of jurisdiction because the petition was not timely filed.
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The notice of deficiency was not mailed to petitioners at their last known address and petitioners did not receive the notice in time to file a timely petition in this Court. Upon receiving a notice of collection of the deficiency for the years involved, petitioners obtained a copy of the notice of deficiency and filed an untimely petition in this Court. Respondent moved to dismiss for lack of jurisdiction because the petition was not timely filed. Petitioners objected and moved to dismiss on the ground that a proper notice of deficiency had not been mailed to them. Held: Under the…
1Opinion of the Court
Emmet N. Shelton and Stella Shelton, Petitioners v. Commissioner of Internal Revenue, Respondent
Shelton v. Commissioner
Docket No. 1835-74
United States Tax Court
63 T.C. 193; 1974 U.S. Tax Ct. LEXIS 21;
November 14, 1974, Filed
The notice of deficiency was not mailed to petitioners at their last known address and petitioners did not receive the notice in time to file a timely petition in this Court. Upon receiving a notice of collection of the deficiency for the years involved, petitioners obtained a copy of the notice of deficiency and filed an untimely petition in this Court. Respondent moved…
2Cases cited25 opinions
- Stoll v. GottliebSupreme Court of the United States · 1938
- Moffat v. CommissionerUnited States Tax Court · 1966
- Lifter v. CommissionerUnited States Tax Court · 1973
- McCormick v. CommissionerUnited States Tax Court · 1970
- Wheeler's Peachtree Pharmacy, Inc. v. CommissionerUnited States Tax Court · 1960
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