Rosenberg v. Commissioner
United States Board of Tax Appeals
A telegram sent to the Board in behalf of a taxpayer, less than 90 days after notice of deficiency had been mailed to him, as follows: "File this as tentative petition I. J. Rosenberg Transferee", is insufficient to give the Board jurisdiction of the controversy.
1Opinion of the Court
*619OPINION.
Seawei-l:
This is a motion by respondent to dismiss this proceeding on the grounds that the Board of Tax Appeals is without jurisdiction to hear and determine the same. The facts are not in dispute.
On September 11, 1934, the Commissioner of Internal Revenue mailed, in the manner provided by law, a notice to the petitioner reading as follows:
IT:E: Aj
COP-21695-90D
SEP 11 1934.
Mr. I. J. ROSENBERG,
Transferee, 2477 North Qramt Boulevard, Milwaukee, Wisconsin.
Sir: In accordance with the provisions of Sections 270(a) and 280 of the Revenue Act of 1926, and Sections 273(a) and 311 of the…
2Cited by5 opinions
- Joannou v. CommissionerUnited States Tax Court · 1960
- Continental Petroleum Co. v. United StatesCourt of Appeals for the Tenth Circuit · 1936
- Blum v. CommissionerUnited States Tax Court · 1986
- Blum v. CommissionerUnited States Tax Court · 1986
- Rosenberg v. CommissionerUnited States Board of Tax Appeals · 1935