Lewy v. Commissioner
United States Tax Court
Petitioner is a resident of France who also maintains an office and apartment in New York City. When the notice of deficiency was mailed to him on Nov. 11, 1976, he was in New York preparing to depart for France the following day.
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Petitioner is a resident of France who also maintains an office and apartment in New York City. When the notice of deficiency was mailed to him on Nov. 11, 1976, he was in New York preparing to depart for France the following day. He left for France on Nov. 12, 1976, and, because of his absence from this country, did not receive actual notice of the deficiency until he next returned to the United States on Feb. 1, 1977. His petition to this Court was mailed on Feb. 10, 1977, the 91st day after the mailing of the deficiency notice. Held: Under sec. 6213(a) petitioner has 150 days within which…
1Opinion of the Court
Claude Lewy, Petitioner v. Commissioner of Internal Revenue, Respondent
Lewy v. Commissioner
Docket No. 1403-77
United States Tax Court
68 T.C. 779; 1977 U.S. Tax Ct. LEXIS 63;
August 29, 1977, Filed
Petitioner is a resident of France who also maintains an office and apartment in New York City. When the notice of deficiency was mailed to him on Nov. 11, 1976, he was in New York preparing to depart for France the following day. He left for France on Nov. 12, 1976, and, because of his absence from this country, did not receive actual notice of the deficiency until he next returned to the United…
2Cases cited26 opinions
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Brooks v. CommissionerUnited States Tax Court · 1975
- William I. Tenzer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Carstenson v. CommissionerUnited States Tax Court · 1972
- King v. CommissionerUnited States Tax Court · 1969
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