Estate of Krueger v. Commissioner
United States Tax Court
Jurisdiction -- 90 or 150 Days for Filing -- Person Outside the United States -- Sec. 272(a)(1), 1939 Code, and Sec. 6213(a), 1954 Code. -- If the person to whom the notice of deficiency is addressed is outside the United States, even temporarily, at the time the notice is mailed, the 150-day period applies. Rebecca S. Hamilton, 13 T.C. 747, modified. Mindell v. Commissioner, 200 F. 2d 38, followed.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner mailed a notice on April 10, 1959, to—
Estate of William Krueger, Deceased
Anna Krueger, Administratrix, and
Mrs. Anna Krueger, Surviving Wife
10230 South Walden Parkway
Chicago 43, Illinois
determining a deficiency in income tax for 1955. Anna filed a petition with the Court for her seif and as Administratrix of William’s estate pursuant to that notice, on August 18, 1959, which was more than 90 days but less than 150 days after the mailing of the notice of deficiency. The Commissioner moved to dismiss the proceeding for lack of jurisdiction on the ground…
2Cases cited2 opinions
- Mindell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Hamilton v. CommissionerUnited States Tax Court · 1949
3Cited by29 opinions
- Looper v. CommissionerUnited States Tax Court · 1980
- Lewy v. CommissionerUnited States Tax Court · 1977
- Camous v. CommissionerUnited States Tax Court · 1977
- Cowan v. CommissionerUnited States Tax Court · 1970
- Degill Corp. v. CommissionerUnited States Tax Court · 1974
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