Alfieri v. Commissioner
United States Tax Court
Held, the fact that respondent did not comply with the requirement of the Administrative Procedures Act, 5 U.S.C. sec. 500, by sending a copy of the notice of deficiency properly mailed to petitioners to petitioners' attorney, does not cause that notice to be invalid, nor does this failure alone without other evidence of improper action by respondent, warrant a conclusion that respondent's determination in the notice is arbitrary.
1Opinion of the Court
Charles A. Alfieri and Jean A. Alfieri, Petitioners v. Commissioner of Internal Revenue, Respondent
Alfieri v. Commissioner
Docket No. 2796-71
United States Tax Court
60 T.C. 296; 1973 U.S. Tax Ct. LEXIS 121; 60 T.C. No. 35;
May 23, 1973, Filed
Decision will be entered for the respondent.
Held, the fact that respondent did not comply with the requirement of the Administrative Procedures Act, 5 U.S.C. sec. 500, by sending a copy of the notice of deficiency properly mailed to petitioners to petitioners' attorney, does not cause that notice to be invalid, nor does this failure alone without other…
2Cases cited6 opinions
- Houghton v. CommissionerUnited States Tax Court · 1967
- Garvey v. FreemanCourt of Appeals for the Tenth Circuit · 1968
- Bunnel v. CommissionerUnited States Tax Court · 1968
- Nappi v. CommissionerUnited States Tax Court · 1972
- St. Paul Bottling Co. v. CommissionerUnited States Tax Court · 1960
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