Greve v. Commissioner
United States Board of Tax Appeals
DEFICIENCY NOTICE - JURISDICTION. - A notice of deficiency mailed by registered mail to an address other than petitioner's and not received by petitioner, but returned by postal authorities to the Commissioner, who remailed it by ordinary mail to petitioner's counsel, held, not a statutory notice of deficiency. Proceeding based on such notice dismissed for want of jurisdiction. Henry Wilson,16 B.T.A. 1280, followed.
1Opinion of the Court
*451OPINION.
Aktjndell:
The facts in this case are quite similar to those in the case of Henry Wilson, 16 B. T. A. 1280. In that case the respondent sent a notice of deficiency by registered mail addressed to Mrs. Henry Wilson at 110 Market St., Oakland, California. She had never lived at that address, and the notice was returned undelivered to the respondent and was remailed by ordinary mail addressed to the petitioner at 110 Market St., San Francisco, California. The latter address was the business address of a partnership of which the petitioner’s husband was a member. The second letter, with…
2Cases cited1 opinion
- Hulburd v. CommissionerSupreme Court of the United States · 1935
3Cited by11 opinions
- Shelton v. CommissionerUnited States Tax Court · 1974
- Heaberlin v. CommissionerUnited States Tax Court · 1960
- Goodman v. CommissionerUnited States Tax Court · 1979
- Gray v. CommissionerUnited States Tax Court · 1944
- Pitcairn v. CommissionerUnited States Tax Court · 1944
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