Cooper v. Commissioner
United States Tax Court
Petitioner filed his petition in this action 114 days after the notice of deficiency was mailed to him at the Baltimore City Jail where he was incarcerated pending posting the requisite collateral for bail, but 89 days after the notice of deficiency was mailed to a residence address known to respondent. Held, the Baltimore City Jail, a temporary address of no definite duration, was not petitioner's last known address.
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Petitioner filed his petition in this action 114 days after the notice of deficiency was mailed to him at the Baltimore City Jail where he was incarcerated pending posting the requisite collateral for bail, but 89 days after the notice of deficiency was mailed to a residence address known to respondent. Held, the Baltimore City Jail, a temporary address of no definite duration, was not petitioner's last known address. Held further, the 90-day period for filing a petition with this Court under sec. 6213(a), I.R.C. 1954, as amended, commenced on the date the notice of deficiency was mailed to…
1Opinion of the Court
VERNON COOPER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Cooper v. Commissioner
Docket No. 27993-83.
United States Tax Court
T.C. Memo 1984-329; 1984 Tax Ct. Memo LEXIS 345; 48 T.C.M. (CCH) 385; T.C.M. (RIA) 84329;
June 27, 1984.
Petitioner filed his petition in this action 114 days after the notice of deficiency was mailed to him at the Baltimore City Jail where he was incarcerated pending posting the requisite collateral for bail, but 89 days after the notice of deficiency was mailed to a residence address known to respondent. Held, the Baltimore City Jail, a temporary address of…
2Cases cited19 opinions
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Frieling v. CommissionerUnited States Tax Court · 1983
- Alta Sierra Vista, Inc. v. CommissionerUnited States Tax Court · 1974
- Lifter v. CommissionerUnited States Tax Court · 1973
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