Legal Opinion

Leventis v. Commissioner

United States Tax Court

Decided January 17, 1968No. Docket Nos. 2834-67, 2835-67PublishedCited by 32 opinions

Postage meter stamp date accepted as postmark date. Petition timely filed. Respondent's motion to dismiss for lack of jurisdiction denied.

1Opinion of the Court

OPINION

Drennen, Judge:

The notices of deficiency in the above two related cases were mailed to petitioners at their respective addresses in Columbia, S.C., on March 10,1967. Separate petitions for the taxpayers, both executed on June 8,1967, were received by the Tax Court of the United States in Washington, D.C., in a single envelope a few minutes after 9 a.m., on Monday, June 12, 1967, and were filed by the Court on that date, which was 94 days after the date of the mailing of the notices of deficiency.

The envelope containing the two petitions bore the return address of a certified public…

2Cited by32 opinions

  1. Sylvan v. CommissionerUnited States Tax Court · 1975
  2. Fishman v. CommissionerUnited States Tax Court · 1969
  3. Stewart v. CommissionerUnited States Tax Court · 1970
  4. Levy v. CommissionerUnited States Tax Court · 1981
  5. Ruegsegger v. CommissionerUnited States Tax Court · 1977

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