Pietanza v. Commissioner
United States Tax Court
Petitioners and respondent each moved to dismiss the petition for redetermination of petitioners' 1980 Federal income tax for lack of jurisdiction: petitioners on the ground that no valid notice of deficiency had been issued; respondent on the ground that petitioners had not filed their petition within the time set forth in sec. 6213. Petitioners did not receive a notice of deficiency.
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Petitioners and respondent each moved to dismiss the petition for redetermination of petitioners' 1980 Federal income tax for lack of jurisdiction: petitioners on the ground that no valid notice of deficiency had been issued; respondent on the ground that petitioners had not filed their petition within the time set forth in sec. 6213. Petitioners did not receive a notice of deficiency. Respondent has lost the administrative file for petitioners' 1980 year and is unable to supply a copy of a notice of deficiency but he has placed into evidence postal service Form 3877, indicating a certified…
1Opinion of the Court
Peter and Mary Pietanza, Petitioners v. Commissioner of Internal Revenue, Respondent
Pietanza v. Commissioner
Docket No. 29531-87
United States Tax Court
92 T.C. 729; 1989 U.S. Tax Ct. LEXIS 46; 92 T.C. No. 41;
March 30, 1989. March 30, 1989, Filed
Petitioners and respondent each moved to dismiss the petition for redetermination of petitioners' 1980 Federal income tax for lack of jurisdiction: petitioners on the ground that no valid notice of deficiency had been issued; respondent on the ground that petitioners had not filed their petition within the time set forth in sec. 6213. Petitioners did not…
Also in this document: Dissent.
2Cases cited30 opinions
- United States v. Chemical Foundation, Inc.Supreme Court of the United States · 1926
- Flora v. United StatesSupreme Court of the United States · 1960
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- Cool Fuel, Incorporated v. William H. Connett, Etc.Court of Appeals for the Ninth Circuit · 1982
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
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