Legal Opinion

Walter N. Lindemood and Clara Lindemood v. Commissioner of Internal Revenue, Ramona T. Galeno v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided December 23, 1977No. 75-2762 and 75-2763PublishedCited by 20 opinions

1Per curiam

The taxpayers in these consolidated cases appeal from orders of the Tax Court dismissing their petitions for redetermination of deficiencies assessed by the Internal Revenue Service (IRS). Because the petitions were not filed within 90 days of the mailing of the notices of deficiency, as required, by 26 U.S.C. § 6213(a) 1 the Tax Court dismissed them for lack of jurisdiction. Pursuant to 26 U.S.C. § 7482, we have jurisdiction to hear the taxpayers’ appeals. We affirm the decision of the Tax Court, which is reported at 34 CCH Tax Ct.Mem.Dec. 839 (1975).

On May 10, 1974, the IRS mailed to Walter…

2Cases cited3 opinions

  1. Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
  2. Fishman v. CommissionerUnited States Tax Court · 1969
  3. Irving and Helen Fishman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970

3Cited by20 opinions

  1. James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
  2. Grigoryan v. Experian Information Solutions, Inc.District Court, C.D. California · 2014
  3. Kahle v. CommissionerUnited States Tax Court · 1987
  4. Dandino, Inc. v. U.S. Department of TransportationCourt of Appeals for the Ninth Circuit · 2013
  5. Edward E. Rotenberry and Jolyne M. Rotenberry v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988

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