Blank v. Commissioner
United States Tax Court
On the 90th day after respondent mailed the notice of deficiency to petitioners, their petition to this Court was placed into the hands of a private delivery service, which hand-delivered it to the Court on the 91st day. Held, the timely mailing as timely filing provisions of sec. 7502, I.R.C. 1954, are inapplicable, and the petition was not timely filed as required by sec. 6213(a).
1Opinion of the Court
Mervyn Blank and June Blank, Petitioners v. Commissioner of Internal Revenue, Respondent
Blank v. Commissioner
Docket No. 13566-80
United States Tax Court
76 T.C. 400; 1981 U.S. Tax Ct. LEXIS 164;
February 26, 1981, Filed
On the 90th day after respondent mailed the notice of deficiency to petitioners, their petition to this Court was placed into the hands of a private delivery service, which hand-delivered it to the Court on the 91st day. Held, the timely mailing as timely filing provisions of sec. 7502, I.R.C. 1954, are inapplicable, and the petition was not timely filed as required by sec.…
2Cases cited10 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Lifter v. CommissionerUnited States Tax Court · 1973
- Keeton v. CommissionerUnited States Tax Court · 1980
- O'Brien v. CommissionerUnited States Tax Court · 1974
- Estate of Cerrito v. CommissionerUnited States Tax Court · 1980
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