Legal Opinion
Stebbins' Estate v. Helvering
Court of Appeals for the D.C. Circuit
Decided April 28, 1941No. 7651PublishedCited by 28 opinions
1Opinion of the CourtGroner, C. J.
In this case the Board of Tax Appeals declined jurisdiction because the petition for redetermination was not filed with the Board within 90 days after the mailing of the deficiency notice. 1 No other question is involved.
The facts are these. Notice of deficiency was mailed by the Commissioner January 18, 1939. The statutory 90 days expired April 18. On April 17, from Miami, Florida, counsel for petitioner sent a telegram to the Board reading as follows: “Petition requesting determination of status of transfer of certain stock by deceased in Matter of Estate of Bliss Stebbins— Grace Cole…
2Cases cited4 opinions
- Poynor v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1936
- Lewis-Hall Iron Works v. BlairCourt of Appeals for the D.C. Circuit · 1928
- Edward Barron Estate Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1937
- Chambers v. LucasCourt of Appeals for the D.C. Circuit · 1930
3Cited by28 opinions
- Edouard Legille v. C. Marshall Dann, Commissioner of PatentsCourt of Appeals for the D.C. Circuit · 1976
- Robert F. McPartlin and Geraldine McPartlin v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1981
- William J. Crum v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1980
- Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Central Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
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