Burford v. Commissioner
United States Tax Court
Respondent issued a notice of deficiency for gift tax for the tax year which ended Dec. 31, 1976. The proper taxable period was the calendar quarter which ended Dec. 31, 1976. Held, the notice of deficiency is not invalid because of a typographical error where the deficiency notice sent fully encompassed the proper taxable period, and the petitioner is not misled as to the period covered.
1Opinion of the Court
S. Franklin Burford, Petitioner v. Commissioner of Internal Revenue, Respondent
Burford v. Commissioner
Docket No. 8330-80
United States Tax Court
76 T.C. 96; 1981 U.S. Tax Ct. LEXIS 189;
January 19, 1981, Filed
Respondent issued a notice of deficiency for gift tax for the tax year which ended Dec. 31, 1976. The proper taxable period was the calendar quarter which ended Dec. 31, 1976. Held, the notice of deficiency is not invalid because of a typographical error where the deficiency notice sent fully encompassed the proper taxable period, and the petitioner is not misled as to the period covered.
S.…
2Cases cited9 opinions
- Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
- Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
- St. Paul Bottling Co. v. CommissionerUnited States Tax Court · 1960
- Estate of Frank D. Stranahan, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973
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