Legal Opinion

Burford v. Commissioner

United States Tax Court

Decided January 19, 1981No. Docket No. 8330-80PublishedCited by 12 opinions

Respondent issued a notice of deficiency for gift tax for the tax year which ended Dec. 31, 1976. The proper taxable period was the calendar quarter which ended Dec. 31, 1976. Held, the notice of deficiency is not invalid because of a typographical error where the deficiency notice sent fully encompassed the proper taxable period, and the petitioner is not misled as to the period covered.

1Opinion of the Court

OPINION

Dawson, Judge:

This case was assigned to Special Trial Judge Francis J. Cantrel for the purpose of conducting the hearing and ruling on petitioner’s motion to dismiss for lack of jurisdiction. After a review of the record, we agree with and adopt his opinion which is set forth below.1

OPINION OF THE SPECIAL TRIAL JUDGE

Cantrel, Special Trial Judge:

This case is presently before the Court on petitioner’s motion to dismiss for lack of jurisdiction filed on June 2,1980.

Respondent, in his notice of deficiency issued to petitioner on March 27, 1980, determined a deficiency of $73,326.20 in…

2Cases cited8 opinions

  1. Sanderling, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
  2. Sanderling, Inc. v. CommissionerUnited States Tax Court · 1976
  3. Commissioner of Internal Revenue v. Forest Glen C. Co.Court of Appeals for the Seventh Circuit · 1938
  4. St. Paul Bottling Co. v. CommissionerUnited States Tax Court · 1960
  5. Estate of Frank D. Stranahan, Deceased v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1973

3 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. Page v. CommissionerUnited States Tax Court · 1986
  2. Century Data Systems, Inc. v. CommissionerUnited States Tax Court · 1983
  3. Shell Oil Co. v. CommissionerUnited States Tax Court · 1988
  4. Dees v. Comm'rUnited States Tax Court · 2017
  5. Miles Production Co. v. CommissionerUnited States Tax Court · 1991

7 more not listed; retrieve them via the Exa API.

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