Grubaugh v. Commissioner
United States Tax Court
P attempts to place tax years 1979-1984 at dispute in this Court. Tax years 1979 and 1980 were closed out by Order of Dismissal and Decision entered on August 24, 1983 from which no appeal was taken. No notice of deficiency was issued to P for tax years 1982-1984. Sec. 6212, I.R.C. 1954. Petition for tax year 1981 not timely filed. Secs. 6213 and 7502, I.R.C. 1954. Held, R's Motion to Dismiss for Lack of Jurisdiction is granted.
1Opinion of the Court
TONY GRUBAUGH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Grubaugh v. Commissioner
Docket No. 1707-85.
United States Tax Court
T.C. Memo 1986-28; 1986 Tax Ct. Memo LEXIS 584; 51 T.C.M. (CCH) 324; T.C.M. (RIA) 86028;
January 22, 1986.
P attempts to place tax years 1979-1984 at dispute in this Court. Tax years 1979 and 1980 were closed out by Order of Dismissal and Decision entered on August 24, 1983 from which no appeal was taken. No notice of deficiency was issued to P for tax years 1982-1984. Sec. 6212, I.R.C. 1954. Petition for tax year 1981 not timely filed. Secs. 6213 and 7502,…
2Cases cited12 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
- National Committee to Secure Justice, etc. v. CommissionerUnited States Tax Court · 1957
- Estate of Rosenberg v. CommissionerUnited States Tax Court · 1980
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