Legal Opinion
William D. Armstrong v. Commissioner of Internal Revenue
Court of Appeals for the Tenth Circuit
Decided February 2, 1994No. 92-9014PublishedCited by 51 opinions
1Opinion of the Court
BALDOCK, Circuit Judge.
Petitioner appeals the order of the United States Tax Court dismissing his petition as untimely. We have jurisdiction pursuant to I.R.C. § 7482, and we affirm.
On March 2, 1990, the Internal Revenue Service (“IRS”) sent by certified mail a notice of deficiency to Petitioner for his individual tax liability for the 1985 and 1986 tax years. The notice was addressed to P.O. Box 35343, Tulsa, Oklahoma, the address the IRS determined was Petitioner’s “last known address” within the meaning of I.R.C. § 6212(b)(1). On March 22, 1990, after leaving two certified mail notices in…
2Cases cited15 opinions
- Pullman-Standard v. SwintSupreme Court of the United States · 1982
- Laing v. United StatesSupreme Court of the United States · 1976
- Monge v. CommissionerUnited States Tax Court · 1989
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Guthrie v. SawyerCourt of Appeals for the Tenth Circuit · 1992
10 more not listed; retrieve them via the Exa API.
3Cited by51 opinions
- Personette v. Kennedy (In Re Midgard Corp.)Bankruptcy Appellate Panel of the Tenth Circuit · 1997
- Frymire v. Ampex Corp.Court of Appeals for the Tenth Circuit · 1995
- United States v. McCallCourt of Appeals for the Tenth Circuit · 2000
- Samuel Anderson and Mary Anderson v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1995
- Czajkowski v. Tindall & Associates, P.C.District Court, E.D. Michigan · 1997
46 more not listed; retrieve them via the Exa API.