Rosenberg v. Commissioner
United States Board of Tax Appeals
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
- Rosenberg v. CommissionerUnited States Board of Tax Appeals · 1935