Lerer v. Commissioner
United States Tax Court
A "Form 7900" letter sent by ordinary mail to a bankrupt in care of the trustee in bankruptcy informing the trustee that respondent proposes to assess deficiencies in income tax against the bankrupt for years prior to the one in which the petition in bankruptcy was filed under the provisions of the Internal Revenue Code relating to bankruptcy is not a notice of deficiency to the individual within the meaning of secs. 6212 and 6213, I.R.C. 1954.
1Opinion of the Court
OPINION
Scott, Judge:
On November 25,1968, respondent filed a motion to dismiss the above-entitled case for lack of jurisdiction on the ground that no statutory notice of deficiency authorized by section 6212,1.R.C. 1954,1 and required by section 6213 (a) to form the basis for an appeal to this Oourt has been sent to petitioner with respect to the taxable years alleged to be in issue in the petition filed in this ease. Respondent in his motion stated that the alleged notice of deficiency dated March 27, 1968, was in fact a “Form 7900 Letter” which is merely a notification that an assessment has…
2Cases cited11 opinions
- King v. CommissionerUnited States Tax Court · 1969
- Prather v. CommissionerUnited States Tax Court · 1968
- Orenduff v. CommissionerUnited States Tax Court · 1968
- St. Paul Bottling Co. v. CommissionerUnited States Tax Court · 1960
- Davison v. CommissionerUnited States Tax Court · 1949
6 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Keeton v. CommissionerUnited States Tax Court · 1980
- Shelton v. CommissionerUnited States Tax Court · 1974
- O'Brien v. CommissionerUnited States Tax Court · 1974
- Fehrs v. CommissionerUnited States Tax Court · 1975
- Abrams v. CommissionerUnited States Tax Court · 1985
35 more not listed; retrieve them via the Exa API.