Legal Opinion

Ramirez v. Commissioner

United States Tax Court

Decided September 23, 1986No. Docket No. 12373-85Published

Under authority of sec. 6851 respondent made a termination assessment against petitioner, a Colombian citizen. Respondent failed to mail a notice of deficiency to petitioner within 60 days of the due date of petitioner's income tax return. Respondent subsequently mailed duplicate notices of deficiency to petitioner. Held: Sec. 6851(b) does not constitute a separate period of limitation for the mailing of a notice of deficiency.

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Under authority of sec. 6851 respondent made a termination assessment against petitioner, a Colombian citizen. Respondent failed to mail a notice of deficiency to petitioner within 60 days of the due date of petitioner's income tax return. Respondent subsequently mailed duplicate notices of deficiency to petitioner. Held: Sec. 6851(b) does not constitute a separate period of limitation for the mailing of a notice of deficiency. Therefore, the notices of deficiency mailed to petitioner are valid provided one was mailed to petitioner's last known address. Secs. 6501(a), (c)(3), 6851(b), I.R.C.…

1Opinion of the Court

Alvaro Ramirez, Petitioner v. Commissioner of Internal Revenue, Respondent

Ramirez v. Commissioner

Docket No. 12373-85

United States Tax Court

87 T.C. 643; 1986 U.S. Tax Ct. LEXIS 50; 87 T.C. No. 38;

September 23, 1986, Filed

Under authority of sec. 6851 respondent made a termination assessment against petitioner, a Colombian citizen. Respondent failed to mail a notice of deficiency to petitioner within 60 days of the due date of petitioner's income tax return. Respondent subsequently mailed duplicate notices of deficiency to petitioner. Held: Sec. 6851(b) does not constitute a separate period of…

2Cases cited15 opinions

  1. Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
  2. Lifter v. CommissionerUnited States Tax Court · 1973
  3. Looper v. CommissionerUnited States Tax Court · 1980
  4. Weinroth v. CommissionerUnited States Tax Court · 1980
  5. Houghton v. CommissionerUnited States Tax Court · 1967

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