Legal Opinion
C. Louis Wood and Hallie D. Wood v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided November 13, 1964No. 19276PublishedCited by 97 opinions
1Opinion of the Court
POPE, Circuit Judge.
This is a petition to review an order of the Tax Court which dismissed appellant’s petition for redetermination of a deficiency determined by the Commissioner of Internal Revenue. The petition was dismissed on the ground that it was not filed within the statutory period following the Commissioner’s notice of deficiency.
The facts are that on March 29, 1963, a notice of tax deficiency determined by the Commissioner was mailed to petitioners. Under § 6213 of the Internal Revenue Code petitioners had 90 days thereafter within which to file with the Tax Court a petition for…
2Cases cited4 opinions
- Dyer v. MacDougallCourt of Appeals for the Second Circuit · 1952
- National Labor Relations Board v. Howell Chevrolet Co.Court of Appeals for the Ninth Circuit · 1953
- Thomas and Delilah Boccuto v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
- Bernard Bloch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
3Cited by97 opinions
- Gladys T. Geiger v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
- Sylvan v. CommissionerUnited States Tax Court · 1975
- James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
- Sparkman v. CommissionerCourt of Appeals for the Ninth Circuit · 2007
- George K. Drake and Charlene C. Drake v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Fifth Circuit · 1977
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