Legal Opinion

Axe v. Commissioner

United States Tax Court

Decided May 9, 1972No. Docket No. 218-72Published

On Sept. 28, 1971, respondent mailed to petitioners a statutory notice of deficiency covering Federal income taxes for the years 1968 and 1969. On Dec. 20, 1971, the petitioners, acting through their accountant, prepared an informal petition on the explanation of adjustments page attached to the notice of deficiency and sent it by first-class mail in an envelope addressed to the "Internal Revenue Service, Attention: Tax Court of United States, 200 No. Los Angeles, Calif."

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On Sept. 28, 1971, respondent mailed to petitioners a statutory notice of deficiency covering Federal income taxes for the years 1968 and 1969. On Dec. 20, 1971, the petitioners, acting through their accountant, prepared an informal petition on the explanation of adjustments page attached to the notice of deficiency and sent it by first-class mail in an envelope addressed to the "Internal Revenue Service, Attention: Tax Court of United States, 200 No. Los Angeles, Calif." The petition was received on Dec. 28, 1971, by the Notices Section, Audit Division, Internal Revenue Service, in Los…

1Opinion of the Court

Baker L and Helen D. Axe, Petitioners v. Commissioner of Internal Revenue, Respondent

Axe v. Commissioner

Docket No. 218-72

United States Tax Court

58 T.C. 256; 1972 U.S. Tax Ct. LEXIS 129;

May 9, 1972, Filed

On Sept. 28, 1971, respondent mailed to petitioners a statutory notice of deficiency covering Federal income taxes for the years 1968 and 1969. On Dec. 20, 1971, the petitioners, acting through their accountant, prepared an informal petition on the explanation of adjustments page attached to the notice of deficiency and sent it by first-class mail in an envelope addressed to the "Internal…

2Cases cited5 opinions

  1. Moffat v. CommissionerUnited States Tax Court · 1966
  2. Axe v. CommissionerUnited States Tax Court · 1972
  3. Rappaport v. CommissionerUnited States Tax Court · 1971
  4. Lurkins v. CommissionerUnited States Tax Court · 1968
  5. Matteson Co. v. CommissionerUnited States Board of Tax Appeals · 1925

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