Edward J. Healy v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
1Opinion of the Court
BARNES, Circuit Judge:
This is an appeal from an order of the Tax Court dismissing a “plea” for return of taxes. 1
Petitioner filed his 1957,1958 and 1959 tax returns after “conferences,” and, so he states, “approval” of counter clerks employed by the Collector of Internal Revenue. As he states: “The Clerks assured petitioner that all submissions would be ‘OK’d’ and that there would be no aftermath.”
There was.
On January 19,1962, the Commissioner sent a notice of deficiency for those years, by certified mail to the last known address of petitioner — Box 1305, Los Angeles, California. Petitioner…
2Cases cited5 opinions
- Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Bernard Bloch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Di Prospero v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1949
- Royal E. Jorgensen and Mary M. Jorgensen v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
3Cited by29 opinions
- Abeles v. CommissionerUnited States Tax Court · 1988
- James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Skillo v. United StatesUnited States Court of Federal Claims · 2005
- Estate of McKaig v. CommissionerUnited States Tax Court · 1968
- August v. CommissionerUnited States Tax Court · 1970
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