Mindell v. Commissioner of Internal Revenue

The Internal Revenue Code, 26 U.S. C.A., § 272(a) (1), provides that within 90 days after the mailing of a deficiency notice, the taxpayer may file a petition with the Tax Court for a redetermination of the deficiency. The final sentence of the paragraph reads:

“If the notice is addressed to a person outside the States of the Union and the District of Columbia, the period specified in this paragraph shall be one hundred and fifty days in lieu of ninety days.”

On March 15, 1951 the Commissioner sent a deficiency notice by registered mail addressed to the taxpayer at his last known address in…