Teitelbaum v. Commissioner
United States Tax Court
Where after making a jeopardy assessment respondent fails to mail his deficiency notice to the taxpayer within 60 days of such assessment but does mail his deficiency notice within the time permitted by the general limitation sections of the Code, a petition filed in the Tax Court within 90 days following the mailing of such deficiency notice establishes jurisdiction in the Court to determine the issues raised by the petition.
1Opinion of the Court
Wtehet, Judge:
Deficiencies in income tax and additions to tax have been determined by respondent as follows:
[[Image here]]
The only issue presented for decision is whether this Court is deprived of jurisdiction where respondent’s service of a deficiency notice upon petitioner was subsequent to 60 days from and after a jeopardy assessment by respondent, but otherwise within the limits fixed by law. The parties have agreed to the amount and nature of the deficiencies and additions to tax should the above issue be decided in favor of the respondent.
BINDINGS OP PACT
Since all of the facts have been…
2Cases cited2 opinions
- Stokes v. CommissionerUnited States Tax Court · 1954
- Berry v. WestoverDistrict Court, S.D. California · 1947
3Cited by7 opinions
- Zaun v. CommissionerUnited States Tax Court · 1974
- Ramirez v. CommissionerUnited States Tax Court · 1986
- Cantu v. CommissionerUnited States Tax Court · 1990
- Cooper v. CommissionerUnited States Tax Court · 1984
- Ramirez v. CommissionerUnited States Tax Court · 1986
2 more not listed; retrieve them via the Exa API.