Mianus Realty Co. v. Commissioner
United States Tax Court
Respondent's motions to dismiss for lack of jurisdiction granted where petitions were filed on the 150th day after statutory notices of deficiencies were mailed to corporate petitioners at their last-known address.
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Respondent's motions to dismiss for lack of jurisdiction granted where petitions were filed on the 150th day after statutory notices of deficiencies were mailed to corporate petitioners at their last-known address. Facts that the only person authorized to act for petitioners was sojourning in Florida on Jan. 27, 1967, the date notices of deficiencies were mailed, left the United States on Feb. 4, 1967, and was out of the country until Apr. 6, 1967, and did not actually receive the notices until about June 15, 1967, do not make the 150-day provision of sec. 6213(a), I.R.C. 1954, applicable.
1Opinion of the Court
Mianus Realty Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; McNeil Brothers, Incorporated, Petitioner v. Commissioner of Internal Revenue, Respondent
Mianus Realty Co. v. Commissioner
Docket Nos. 3137-67, 3199-67
United States Tax Court
50 T.C. 418; 1968 U.S. Tax Ct. LEXIS 114;
June 4, 1968, Filed
Respondent's motions to dismiss for lack of jurisdiction granted where petitions were filed on the 150th day after statutory notices of deficiencies were mailed to corporate petitioners at their last-known address. Facts that the only person authorized to act for petitioners…
2Cases cited10 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Arlington Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Thomas and Delilah Boccuto v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
- Edward J. Healy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1965
- Estate of Krueger v. CommissionerUnited States Tax Court · 1960
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