Legal Opinion

Scruggs v. Commissioner

United States Board of Tax Appeals

Decided February 14, 1934No. Docket No. 69796Published

Where a notice of deficiency is erroneously addressed to a certain individual as administrator of the estate of the deceased taxpayer, which notice clearly shows that the proposed deficiency is asserted against the estate of the deceased taxpayer for the taxable year, and a timely petition for redetermination of the tax is filed with the Board by the duly appointed administratrix of the decedent's estate, containing no allegation with respect to the misnomer in the…

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Where a notice of deficiency is erroneously addressed to a certain individual as administrator of the estate of the deceased taxpayer, which notice clearly shows that the proposed deficiency is asserted against the estate of the deceased taxpayer for the taxable year, and a timely petition for redetermination of the tax is filed with the Board by the duly appointed administratrix of the decedent's estate, containing no allegation with respect to the misnomer in the deficiency notice, it is held that the petitioner has not been misled by the method of addressing and, by appearing before the…

1Opinion of the Court

CORINNE PORTER SCRUGGS, ADMINISTRATRIX OF THE ESTATE OF J. D. SCRUGGS, DECEASED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Scruggs v. Commissioner

Docket No. 69796.

United States Board of Tax Appeals

29 B.T.A. 1102; 1934 BTA LEXIS 1422;

February 14, 1934, Promulgated

Where a notice of deficiency is erroneously addressed to a certain individual as administrator of the estate of the deceased taxpayer, which notice clearly shows that the proposed deficiency is asserted against the estate of the deceased taxpayer for the taxable year, and a timely petition for redetermination of the…

2Cases cited1 opinion

  1. Scruggs v. CommissionerUnited States Board of Tax Appeals · 1934

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