Parker v. Commissioner
United States Tax Court
The petitioners' returns designated one address as that of the petitioners. A power of attorney, later executed, designated another address for the petitioners and directed that "all correspondence, documents, warrants, or other data" in connection with the taxation be sent in care of their attorney, whose address was also given in the power of attorney.
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The petitioners' returns designated one address as that of the petitioners. A power of attorney, later executed, designated another address for the petitioners and directed that "all correspondence, documents, warrants, or other data" in connection with the taxation be sent in care of their attorney, whose address was also given in the power of attorney. Deficiency notices were mailed by registered mail to the address of petitioners given in the power of attorney and recited that copies would be mailed to the attorney at his address as given in the power of attorney. There was no evidence…
1Opinion of the Court
OPINION.
Disney, Judge-.
This matter arises on respondent’s motions to dismiss for lack of jurisdiction, on the ground that the petitions were filed on the ninety-first day after mailing of the notices of deficiency. The petitioners do not controvert that fact, but oppose the motions on the ground that the notices of deficiency were not sent to the petitioners’ last known address. From evidence adduced and stipulations made, we find the facts, which are identical as to each petitioner, to be as follows:
Notice of deficiency was mailed by the Commissioner of Internal Revenue to each of the…
2Cases cited1 opinion
- Hurd v. CommissionerUnited States Tax Court · 1947
3Cited by14 opinions
- Lifter v. CommissionerUnited States Tax Court · 1973
- Robinson v. CommissionerUnited States Tax Court · 1972
- Brzezinski v. CommissionerUnited States Tax Court · 1954
- Houghton v. CommissionerUnited States Tax Court · 1967
- Berger v. CommissionerUnited States Tax Court · 1967
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