Clodfelter v. Commissioner
United States Tax Court
Held, the notice of deficiency, timely received by petitioners, after having been mailed to an address furnished by petitioners' attorney, was mailed to petitioners' last-known address within the meaning of sec. 6212(b), I.R.C. 1954, and the timely petition herein conferred jurisdiction on this Court.
1Opinion of the Court
Featherston, Judge:
Respondent determined deficiencies in petitioners’ income tax for 1960 through 1964 in the total amount of $593,601.50, together with additions to the tax for each year under section 6653(a)1 in the total amount of $29,680.06. Petitioners have filed a motion to dismiss the petition, contending that this Court lacks jurisdiction. The question presented for decision is whether the notice of deficiency was mailed to petitioners’ “last known address” within the meaning of section 6212 (b).
FINDINGS OF FACT
At the time the petition was filed, Floyd R. Clodfelter (sometimes…
2Cases cited17 opinions
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- 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
- McCormick v. CommissionerUnited States Tax Court · 1970
12 more not listed; retrieve them via the Exa API.
3Cited by77 opinions
- Frieling v. CommissionerUnited States Tax Court · 1983
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Lifter v. CommissionerUnited States Tax Court · 1973
- Weinroth v. CommissionerUnited States Tax Court · 1980
- Mulvania v. CommissionerUnited States Tax Court · 1983
72 more not listed; retrieve them via the Exa API.