Hubbard v. Comm'r
United States Tax Court
P executed special consents (Forms 872-A) extending the statute of limitations for the taxable years 1976 through 1979. R issued a notice of deficiency on November 13, 1985 for these tax years. The notice was not sent to P's last known address and not received by him. In April and May of 1986, P became aware of the November 13, 1985 notice of deficiency.
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P executed special consents (Forms 872-A) extending the statute of limitations for the taxable years 1976 through 1979. R issued a notice of deficiency on November 13, 1985 for these tax years. The notice was not sent to P's last known address and not received by him. In April and May of 1986, P became aware of the November 13, 1985 notice of deficiency. R issued a new notice of deficiency for the same tax years to P's last known address on March 31, 1987. A timely petition was filed with respect to this notice. Held, P's Motion for Summary Judgment is granted in that the statute of…
1Opinion of the Court
CHARLES E. HUBBARD, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hubbard v. Comm'r
Docket No. 9008-87.
United States Tax Court
T.C. Memo 1987-575; 1987 Tax Ct. Memo LEXIS 578; 54 T.C.M. (CCH) 1121; T.C.M. (RIA) 87575;
November 23, 1987; Reversed and Remanded April 12, 1989
P executed special consents (Forms 872-A) extending the statute of limitations for the taxable years 1976 through 1979. R issued a notice of deficiency on November 13, 1985 for these tax years. The notice was not sent to P's last known address and not received by him. In April and May of 1986, P became aware of the…
2Cases cited8 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Naftel v. CommissionerUnited States Tax Court · 1985
- Espinoza v. CommissionerUnited States Tax Court · 1982
- Roszkos v. CommissionerUnited States Tax Court · 1986
- Page v. CommissionerUnited States Tax Court · 1986
3 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Charles E. Hubbard v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1989