Legal Opinion
William L. King and Darlene E. King v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided September 21, 1988No. 87-7418PublishedCited by 111 opinions
1Opinion of the Court
POOLE, Circuit Judge:
The Commissioner appeals from the Tax Court’s order dismissing the Kings’ petition for lack of jurisdiction. The Tax Court held that the Commissioner failed to exercise reasonable diligence to ascertain the Kings’ last known address and that therefore the notice of deficiency mailed to the Kings’ former address was invalid. We have jurisdiction pursuant to 26 U.S.C. § 7482 (1982 & Supp. IV 1986) 1 and we affirm.
FACTS AND PROCEEDINGS BELOW
The essential facts are undisputed and are set forth in the Tax Court’s opinion. See King v. Commissioner, 88 T.C. 1042, 1043-46 (1987).…
2Cases cited18 opinions
- United States v. Winston Bryant McConneyCourt of Appeals for the Ninth Circuit · 1984
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Helvering v. Tex-Penn Oil Co.Supreme Court of the United States · 1937
- 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
13 more not listed; retrieve them via the Exa API.
3Cited by111 opinions
- Monge v. CommissionerUnited States Tax Court · 1989
- William D. Armstrong v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1994
- Miller v. CommissionerUnited States Tax Court · 1990
- Saso v. CommissionerUnited States Tax Court · 1989
- Blonien v. Comm'rUnited States Tax Court · 2002
106 more not listed; retrieve them via the Exa API.