Legal Opinion
Lewis E. Johnson and Jeanne K. Johnson v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided February 13, 1980No. 78-1025PublishedCited by 35 opinions
1Opinion of the Court
INGRAHAM, Circuit Judge.
This appeal is before us on a petition to review an order of the Tax Court which dismissed taxpayer’s 1 petition for redetermination of his 1971 and 1972 income taxes. The Tax Court concluded that the Commissioner had properly mailed the notice of deficiency to taxpayer’s last known address and the petition for redetermination had not been filed within the statutory ninety-day period. The court therefore granted the Commissioner’s motion to dismiss the petition for lack of jurisdiction. We reverse.
At all relevant times, taxpayer and his wife have resided at 1342 Robert…
2Cases cited16 opinions
- United States v. United States Gypsum Co.Supreme Court of the United States · 1948
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Roy W. Dewelles v. United States of AmericaCourt of Appeals for the Ninth Circuit · 1967
11 more not listed; retrieve them via the Exa API.
3Cited by35 opinions
- Barrera-Montenegro v. USA & Drug Enforcement AdministrationCourt of Appeals for the Fifth Circuit · 1996
- Frieling v. CommissionerUnited States Tax Court · 1983
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Robert F. McPartlin and Geraldine McPartlin v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Seventh Circuit · 1981
- Keeton v. CommissionerUnited States Tax Court · 1980
30 more not listed; retrieve them via the Exa API.