Hamilton v. Commissioner
United States Tax Court
1. Petitioner Hamilton filed her 1944 income tax return with the collector for the third district of New York. The respondent, on March 10, 1948, by registered mail, sent his notice of deficiency to her at 415 East 51st Street, New York 22, New York. Since April 1945, the petitioner has been a resident of England and of Paris, France, where she resided at the time of the mailing of the deficiency notice.
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1. Petitioner Hamilton filed her 1944 income tax return with the collector for the third district of New York. The respondent, on March 10, 1948, by registered mail, sent his notice of deficiency to her at 415 East 51st Street, New York 22, New York. Since April 1945, the petitioner has been a resident of England and of Paris, France, where she resided at the time of the mailing of the deficiency notice. Her petition was filed on August 6, 1948, 149 days after the mailing of the deficiency notice. Held, that the filing of the petition was timely, under section 272 (a) (1) of the Internal…
1Opinion of the Court
OPINION.
Turner, Judge:
These proceedings were heard on motions of the respondent to dismiss for lack of jurisdiction, on the ground that the petitions were not filed within the period prescribed therefor in section 272 (a) (1) of the Internal Revenue Code.1
Petitioner Rebecca S. Hamilton filed her 1944 income tax return with the collector of internal revenue for the third district of New York. The respondent determined a deficiency of $462.36 in income tax against her for 1944, and on March 10,1948, mailed notice thereof, by registered mail, to her at 415 East 51st Street, New York 22, New…
2Cases cited4 opinions
- Botany Worsted Mills v. United StatesSupreme Court of the United States · 1929
- Carbone v. CommissionerUnited States Tax Court · 1947
- Hurd v. CommissionerUnited States Tax Court · 1947
- Midtown Catering Co. v. CommissionerUnited States Tax Court · 1949
3Cited by25 opinions
- Looper v. CommissionerUnited States Tax Court · 1980
- Clifford O. Boren v. R. A. Riddell, District Director of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Lewy v. CommissionerUnited States Tax Court · 1977
- Estate of Krueger v. CommissionerUnited States Tax Court · 1960
- Mindell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
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