Weston B. Andrews v. Commissioner of Internal Revenue

On June 15, 1976, the Commissioner of Internal Revenue sent to taxpayer’s last known address a “Notice of Deficiency” in connection with taxpayer Weston B. Andrew’s 1974 income tax return. The deficiency resulted from disallowance of a claimed casualty loss carryover “consisting of anticipated medical expenses and loss of potential earnings, past, present and future.” Taxpayer, apparently a victim of certain unrecompensed personal injuries, had claimed the loss on the theory that personal injury losses should be afforded tax treatment equivalent to that afforded property losses. See 26 U.S.C.…