Legal Opinion
Guy Diviaio v. Commissioner of Internal Revenue
Court of Appeals for the D.C. Circuit
Decided July 12, 1976No. 75-1557PublishedCited by 18 opinions
1Opinion of the Court
JAMESON, District Judge:
This is an appeal from a decision of the Tax Court dismissing. the taxpayer’s petition for a redetermination of tax deficiency for failing to file a timely petition.
On September 13, 1974 the Commissioner of Internal Revenue, through his district director in Newark, New Jersey, sent duplicate originals of a statutory notice of deficiency to petitioner, addressed as follows:
“Mr. Guy DiViaio 451 Crystal Lake Avenue Hadden Township, New Jersey 08033 and C/O Warden U.S. Penitentiary Atlanta, Georgia 30315” 1
Petitioner did not at any time receive the notice addressed to…
2Cases cited8 opinions
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
- Lester L. Luhring and Betty W. Luhring v. Clifford W. Glotzbach, District Director of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
- Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Arlington Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
3 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Keeton v. CommissionerUnited States Tax Court · 1980
- Skillo v. United StatesUnited States Court of Federal Claims · 2005
- William J. Crum v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1980
- Lewy v. CommissionerUnited States Tax Court · 1977
- Lewis E. Johnson and Jeanne K. Johnson v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
13 more not listed; retrieve them via the Exa API.