Pendola v. Commissioner
United States Tax Court
The investigation of a widespread conspiracy involving hundreds of taxpayers residing in two adjoining internal revenue districts and also involving many I.R.S. employees of those districts was consolidated under one (Manhattan) of those district directors. Held: The statutory deficiency notice sent to these petitioners, residents of the Brooklyn district, and signed by the district director of the Manhattan district, was good and sufficient.
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The investigation of a widespread conspiracy involving hundreds of taxpayers residing in two adjoining internal revenue districts and also involving many I.R.S. employees of those districts was consolidated under one (Manhattan) of those district directors. Held: The statutory deficiency notice sent to these petitioners, residents of the Brooklyn district, and signed by the district director of the Manhattan district, was good and sufficient. Petitioners' motion to dismiss for lack of jurisdiction is denied. Held, further, from the record, the amounts of income unreported for 1961 and 1962;…
1Opinion of the Court
FoRkesteR, Judge:
Respondent has determined that the petitioners are liable for the following income tax deficiencies and additions to their taxes:
Year Deficiency Addition to tax, sec. 6SSS(.b), I.R.C. 19S4-
$11, 138. 36 $5, 569. 18 1961.
28, 299. 74 14, 149. 87 1962.
At trial respondent conceded the correctness of the itemized deductions petitioners claimed on their 1961 and 1962 income tax returns. At the conclusion of the trial petitioners filed a motion to dismiss for lack of jurisdiction. The following questions now remain for our consideration : Whether we are without jurisdiction because…
2Cases cited22 opinions
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- Gano v. CommissionerUnited States Board of Tax Appeals · 1930
- Howell v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1949
- Ben Perlmutter and Bernice Perlmutter v. Commissioner of Internal Revenue, the Perlmutters, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1967
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