Legal Opinion
Makram A. Tadros v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided May 29, 1985No. 990, Docket 84-4174PublishedCited by 59 opinions
1Opinion of the Court
GEORGE C. PRATT, Circuit Judge:
The sole issue on this appeal is whether a notice of deficiency was mailed to the taxpayer’s “last known address” within the meaning of 26 U.S.C. § 6212(b)(1) so as to require him to file his petition for redetermination in the tax court within 90 days of the mailing. Because we agree with the court below that the taxpayer failed to provide the commissioner with a clear and concise notification of his change in address, we find that the IRS complied with the statute by mailing the notice to the address on the tax return. Accordingly, we affirm.
Background
When in…
2Cases cited9 opinions
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- United States v. Edward J. AhrensCourt of Appeals for the Eighth Circuit · 1976
- Lester L. Luhring and Betty W. Luhring v. Clifford W. Glotzbach, District Director of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
- James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
4 more not listed; retrieve them via the Exa API.
3Cited by59 opinions
- Theede v. United States Department of LaborCourt of Appeals for the Tenth Circuit · 1999
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Pietanza v. CommissionerUnited States Tax Court · 1989
- Conrad Keado v. United States of America, Conrad L. Keado and Linda W. Keado v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- William D. Armstrong v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1994
54 more not listed; retrieve them via the Exa API.