Anderson v. Commissioner
United States Tax Court
All of petitioner's tax liability asserted in a letter purporting to be a notice of deficiency having been paid before the mailing thereof, held that the absence of any "deficiency" within the meaning of Internal Revenue Code, section 271 (a), deprives this Court of jurisdiction, requiring dismissal of the proceeding.
1Opinion of the Court
OPINION.
Opper, Judge'.
The petition purports to challenge a deficiency in income tax said to have been determined for the year 1943 in the amount of $1,097.08. Petitioner filed the return here involved with the collector for the fifth district of New Jersey.
Although neither petitioner nor anyone representing him appeared to prosecute the case, a hearing was had, and upon the evidence so taken respondent filed a motion to dismiss the proceeding for lack of jurisdiction.
The records of the office of the collector of internal revenue for the fifth district of New Jersey in respect to income and…
2Cited by36 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- George M. Still, Inc. v. CommissionerUnited States Tax Court · 1953
- Walsh v. Comm'rUnited States Tax Court · 1954
- Stewart v. CommissionerUnited States Tax Court · 1976
- Standard Oil Company (New Jersey) v. Denis J. McMahon Individually and as District Director of Internal Revenue, Lower ManhattanCourt of Appeals for the Second Circuit · 1957
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