Estate of Cranor v. Commissioner
United States Tax Court
P's counsel deposited an envelope containing P's petition with FedEx on the 87th day after R mailed the notice of deficiency. The envelope bore the correct name, address, and ZIP code for this Court. FedEx held the envelope at a FedEx office rather than delivering it and later returned it to the sender. P's counsel re-sent the petition with FedEx, and the petition was delivered to the Court on the 101st day after the notice of deficiency was sent.
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P's counsel deposited an envelope containing P's petition with FedEx on the 87th day after R mailed the notice of deficiency. The envelope bore the correct name, address, and ZIP code for this Court. FedEx held the envelope at a FedEx office rather than delivering it and later returned it to the sender. P's counsel re-sent the petition with FedEx, and the petition was delivered to the Court on the 101st day after the notice of deficiency was sent. R filed a motion to dismiss for lack of jurisdiction. 1. HELD, the envelope was properly addressed as required by sec. 7502(a)(2)(B), I.R.C. 2.…
1Opinion of the Court
ESTATE OF MARGUERITE M. CRANOR, DECEASED, JOHN R. PHILLIPS, JR., ADMINISTRATOR AD LITEM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Estate of Cranor v. Commissioner
No. 15171-99
United States Tax Court
T.C. Memo 2001-27; 2001 Tax Ct. Memo LEXIS 39; 81 T.C.M. (CCH) 1111; T.C.M. (RIA) 54234;
February 8, 2001, Filed
An appropriate order will be issued.
P's counsel deposited an envelope containing P's petition
with FedEx on the 87th day after R mailed the notice of
deficiency. The envelope bore the correct name, address, and ZIP
code for this Court. FedEx held the envelope at a FedEx office
r…
2Cases cited9 opinions
- Commissioner v. BrownSupreme Court of the United States · 1965
- Commissioner v. SolimanSupreme Court of the United States · 1993
- Axe v. CommissionerUnited States Tax Court · 1972
- Estate of Cerrito v. CommissionerUnited States Tax Court · 1980
- Lurkins v. CommissionerUnited States Tax Court · 1968
4 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Lozier Corp. v. Douglas Cty. Bd. of Equal.Nebraska Supreme Court · 2013