Adkison v. Commissioner
United States Tax Court
Ps live on a remote island in southeastern Alaska, without roads and accessible only by boat or float plane. R mailed a notice of deficiency to Ps at their last known address: "Pouch B, Ketchikan, Alaska 99901". The envelope containing Ps' petition was postmarked by the United States Postal Service on a date 94 days after the mailing of the deficiency notice, and was received by the Court on a date 97 days after the mailing of the deficiency notice.
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Ps live on a remote island in southeastern Alaska, without roads and accessible only by boat or float plane. R mailed a notice of deficiency to Ps at their last known address: "Pouch B, Ketchikan, Alaska 99901". The envelope containing Ps' petition was postmarked by the United States Postal Service on a date 94 days after the mailing of the deficiency notice, and was received by the Court on a date 97 days after the mailing of the deficiency notice. Held: Ps are not persons "outside the United States" and their address is not "outside the United States" within the meaning of sec. 6213(a),…
1Opinion of the Court
GARY A. and ALENE C. ADKISON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Adkison v. Commissioner
Docket No. 29198-91
United States Tax Court
T.C. Memo 1992-411; 1992 Tax Ct. Memo LEXIS 431; 64 T.C.M. (CCH) 239;
July 20, 1992, Filed
An order dismissing the petition for lack of jurisdiction will be entered.
Ps live on a remote island in southeastern Alaska, without roads and accessible only by boat or float plane. R mailed a notice of deficiency to Ps at their last known address: "Pouch B, Ketchikan, Alaska 99901". The envelope containing Ps' petition was postmarked by the United…
2Cases cited8 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Looper v. CommissionerUnited States Tax Court · 1980
- Brown v. CommissionerUnited States Tax Court · 1982
- 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
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