Legal Opinion

Rosenberg v. Commissioner

United States Board of Tax Appeals

Decided May 17, 1935No. Docket Nos. 78062, 78410Published

A telegram sent to the Board in behalf of a taxpayer, less than 90 days after notice of deficiency had been mailed to him, as follows: "File this as tentative petition I. J. Rosenberg Transferee", is insufficient to give the Board jurisdiction of the controversy.

1Opinion of the Court

I. J. ROSENBERG, TRANSFEREE, BANKERS SECURITY COMPANY, TRANSFEROR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Rosenberg v. Commissioner

Docket Nos. 78062, 78410.

United States Board of Tax Appeals

32 B.T.A. 618; 1935 BTA LEXIS 918;

May 17, 1935, Promulgated

A telegram sent to the Board in behalf of a taxpayer, less than 90 days after notice of deficiency had been mailed to him, as follows: "File this as tentative petition I. J. Rosenberg Transferee", is insufficient to give the Board jurisdiction of the controversy.

E. C. Pommerening, Esq., for the petitioner.

J. R. Johnston, Esq.,…

2Cases cited1 opinion

  1. Rosenberg v. CommissionerUnited States Board of Tax Appeals · 1935

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