Hurst, Anthony & Watkins v. Commissioner
United States Board of Tax Appeals
An appeal must be filed within 60 days of the date of mailing of the notice of deficiency by the Commissioner of Internal Revenue, or the Board of Tax Appeals is without jurisdiction to entertain the appeal.
1Opinion of the Court
Graupner :
The Commissioner moved to dismiss this appeal upon the ground that the Board was without jurisdiction on account of the petition not having been filed within 60 days after the mailing of the deficiency notice by the Commissioner to the taxpayer. The essential facts for consideration are as follows:
The Commissioner of Internal Revenue mailed the notice of deficiency to the above-named taxpayer on July 7, 1924. The notice was inclosed in an official envelope addressed to the taxpayer at 316 Fourth Avenue, Pittsburgh, Pa. The notice bore no date upon its face. However, it was received…
2Cited by8 opinions
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- Jones v. CommissionerUnited States Tax Court · 1984
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