Legal Opinion

Guralnik v. Comm'r

United States Tax Court

Decided June 2, 2016No. Docket No. 4358-15LPublishedCited by 11 opinions

R mailed P a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On February 13, 2015, P sent his petition to this Court via Federal Express First Overnight service, which was not then a "designated delivery service" under I.R.C. sec. 7502(f)(2). P's petition was required to be filed "within 30 days of a determination under this section."

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R mailed P a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On February 13, 2015, P sent his petition to this Court via Federal Express First Overnight service, which was not then a "designated delivery service" under I.R.C. sec. 7502(f)(2). P's petition was required to be filed "within 30 days of a determination under this section." I.R.C. sec. 6330(d)(1). On the last date for timely filing of the petition, Tuesday, February 17, 2015, all Federal Government offices in the District of Columbia, including the Tax Court, were officially closed on account…

1Opinion of the Court

FELIX GURALNIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Guralnik v. Comm'r

Docket No. 4358-15L.

United States Tax Court

146 T.C. 230; 2016 U.S. Tax Ct. LEXIS 16; 146 T.C. No. 15;

June 2, 2016, Filed

An order will be issued denying respondent's motion to dismiss for lack of jurisdiction.

R mailed P a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. On February 13, 2015, P sent his petition to this Court via Federal Express First Overnight service, which was not then a "designated delivery service" under I.R.C. sec. 7502(f)(2). P's petition was…

2Cases cited59 opinions

  1. Arbaugh v. Y & H Corp.Supreme Court of the United States · 2006
  2. Irwin v. Department of Veterans AffairsSupreme Court of the United States · 1991
  3. Kontrick v. RyanSupreme Court of the United States · 2004
  4. Henderson v. ShinsekiSupreme Court of the United States · 2011
  5. United States v. DalmSupreme Court of the United States · 1990

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3Cited by11 opinions

  1. Myers v. Comm'r of Internal Revenue ServiceCourt of Appeals for the D.C. Circuit · 2019
  2. Organic Cannabis Foundation v. CirCourt of Appeals for the Ninth Circuit · 2020
  3. Tilden v. CommissionerCourt of Appeals for the Seventh Circuit · 2017
  4. Matuszak v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2017
  5. Duggan v. CommissionerCourt of Appeals for the Ninth Circuit · 2018

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