Legal Opinion
The Manchester Group Subsidiaries, Formerly Torrey Development Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided May 19, 1997No. 95-70422PublishedCited by 13 opinions
1Opinion of the Court
OPINION
2Per curiam
Does the Tax Court have jurisdiction to consider a motion for leave to file a motion to vacate where a taxpayer mailed the motion within the time for filing, but the motion was received after the time for filing had passed? The answer is “yes.”
FACTS
The Commissioner of Internal Revenue (“Commissioner”) mailed a tax deficiency notice to The Manchester Group (“Manchester”). Manchester responded with a petition to the Tax Court for redetermination.
The parties subsequently submitted a stipulation for entry of decision in which the Commissioner conceded the entire deficiency. The decision,…
3Cases cited7 opinions
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Bessie Lasky and Jesse L. Lasky v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Peter Billingsley v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- William G. Nordvik Claire N. Nordvik v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1995
- Bernard Bloch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
2 more not listed; retrieve them via the Exa API.
4Cited by13 opinions
- Stewart v. Comm'rUnited States Tax Court · 2006
- Spencer Medical Associates. v. CommissionerCourt of Appeals for the Fourth Circuit · 1998
- Cowan v. Comm'rUnited States Tax Court · 2006
- Golditch v. Comm'rUnited States Tax Court · 2006
- Hoffman v. Comm'rUnited States Tax Court · 2006
8 more not listed; retrieve them via the Exa API.