Williams v. Commissioner
United States Tax Court
1. Where the communication relied on by petitioner as the statutory deficiency notice is not shown to have been sent to him by registered mail, the Tax Court is without jurisdiction of a proceeding grounded thereon. 2. The jurisdiction of the Tax Court does not include matters relating to the enforcement of warrants for distraint. Accordingly, a motion for the entry of an order to stay the enforcement of such a warrant will be dismissed for lack of jurisdiction.
1Opinion of the Court
OPINION.
Turner, Judge:
This proceeding was heard on the respondent’s motion to dismiss for lack of jurisdiction on the ground that the petition does not purport to be taken from a notice of deficiency, but from a revenue agent’s report and a transmittal letter from the acting internal revenue agent in charge forwarding a copy of the report to the petitioner.
The original petition was filed on April 5, 1949, and an amended petition was filed on April 18, 1949. Attached to each, as Exhibit A, is a copy of a transmittal letter dated February 9, 1949, from the acting internal fevenue agent in…
2Cases cited1 opinion
- Midtown Catering Co. v. CommissionerUnited States Tax Court · 1949
3Cited by4 opinions
- Brzezinski v. CommissionerUnited States Tax Court · 1954
- Brzezinski v. CommissionerUnited States Tax Court · 1954
- Mori v. CommissionerUnited States Tax Court · 1982
- Williams v. CommissionerUnited States Tax Court · 1949