Legal Opinion

Mollet v. Commissioner

United States Tax Court

Decided April 18, 1984No. Docket No. 3633-83Published

Under the facts presented: Held, that petitioner has failed to prove that he gave respondent clear and concise oral notification of a change of address to Florida from Minnesota prior to the issuance of respondent's statutory notice for the years 1978 and 1979. Held, further, that petitioner failed to prove he had given such notice through the filing of returns for 1980 and 1981 showing a Florida address.

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Under the facts presented: Held, that petitioner has failed to prove that he gave respondent clear and concise oral notification of a change of address to Florida from Minnesota prior to the issuance of respondent's statutory notice for the years 1978 and 1979. Held, further, that petitioner failed to prove he had given such notice through the filing of returns for 1980 and 1981 showing a Florida address. Held, further: That petitioner's allegation of a Florida legal residence in a petition filed with the Court in another case, and served on respondent's counsel by the Court, does not…

1Opinion of the Court

Merlin L. Mollet, Petitioner v. Commissioner of Internal Revenue, Respondent

Mollet v. Commissioner

Docket No. 3633-83

United States Tax Court

82 T.C. 618; 1984 U.S. Tax Ct. LEXIS 81; 82 T.C. No. 49;

April 18, 1984, Filed

An appropriate order of dismissal for lack of jurisdiction will be entered.

Under the facts presented: Held, that petitioner has failed to prove that he gave respondent clear and concise oral notification of a change of address to Florida from Minnesota prior to the issuance of respondent's statutory notice for the years 1978 and 1979. Held, further, that petitioner failed to prove…

2Cases cited29 opinions

  1. Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
  2. United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
  3. Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
  4. Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
  5. Moffat v. CommissionerUnited States Tax Court · 1966

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