Levitt v. Commissioner
United States Tax Court
H filed the petition in this case, signing his and W's names on it. W did not authorize H to sign the petition on her behalf. W claims that the returns that H filed were not valid joint Federal income tax returns and that the notice of deficiency was invalid as to W. Held: Because W is not a party to this case, we do not decide whether the statutory notice of deficiency was valid as to her.
1Opinion of the Court
OPINION
COHEN, Judge:
Through the circumstances described below, it is now apparent that the Court lacks jurisdiction over Simone H. Levitt in this case. The parties disagree, however, as to the ground to be stated in our order dismissing the petition as to her.
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect at the time the petition was filed, and all Rule references are to the Tax Court Rules of Practice and Procedure. Some of the facts have been stipulated, and the stipulated facts are incorporated herein by this reference.
Background
2Cases cited15 opinions
- Flora v. United StatesSupreme Court of the United States · 1960
- Pyo v. CommissionerUnited States Tax Court · 1984
- Pietanza v. CommissionerUnited States Tax Court · 1989
- Keeton v. CommissionerUnited States Tax Court · 1980
- Shelton v. CommissionerUnited States Tax Court · 1974
10 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Smith v. CommissionerUnited States Tax Court · 2013
- Schoenfeld v. CommissionerUnited States Tax Court · 1993
- Stinnett v. CommissionerUnited States Tax Court · 1993
- Kruszynski v. CommissionerUnited States Tax Court · 1993
- Levitt v. CommissionerUnited States Tax Court · 1993
13 more not listed; retrieve them via the Exa API.