Legal Opinion
Di Prospero v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided June 22, 1949No. 12098PublishedCited by 19 opinions
1Per curiam
On January 9, 1948, the Commissioner of Internal Revenue mailed a notice of tax deficiency for the years 1942 to 1945 to petitioner. The applicable law 1 permits the taxpayer to file a petition for redetermination of the deficiency with the Tax Court within 90 days of the mailing of the notice, the 90th day in this case being April 8, 1948. On April 6, petitioner’s counsel mailed the petition, air mail, special delivery, from San Francisco. The petition arrived in Washington D. C., at about 2:45 on the afternoon of April 8th and the messenger bearing the petition, arrived at the Tax Court…
2Cases cited5 opinions
- Lewis-Hall Iron Works v. BlairCourt of Appeals for the D.C. Circuit · 1928
- Stebbins' Estate v. HelveringCourt of Appeals for the D.C. Circuit · 1941
- Edward Barron Estate Co. v. Commissioner of Int. Rev.Court of Appeals for the Ninth Circuit · 1937
- Goldsmith v. United States Board of Tax AppealsCourt of Appeals for the D.C. Circuit · 1925
- American Security & Trust Co. v. MuseCourt of Appeals for the D.C. Circuit · 1894
3Cited by19 opinions
- Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Central Paper Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1952
- Bernard Bloch v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Eppler v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1951
- Edward J. Healy v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1965
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