Legal Opinion
Richard L. Mulvania v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 27, 1985No. 84-7359PublishedCited by 44 opinions
1Opinion of the Court
GOODWIN, Circuit Judge.
The Commissioner of the Internal Revenue Service appeals a decision of the Tax Court that it lacked jurisdiction to assess a deficiency against taxpayer, Richard L. Mulvania, because he did not receive a valid notice of deficiency within the three-year statute of limitations on assessments. We affirm.
Mulvania timely filed an income tax return for 1977 showing his address as 57 Linda Isle Drive, Newport Beach, California. The return was prepared by Gerald F. Simonis Accountants, Inc. On June 13, 1979, the IRS sent a letter to Mulvania setting forth proposed adjustments…
2Cases cited10 opinions
- Lifter v. CommissionerUnited States Tax Court · 1973
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
- Roy W. Dewelles v. United States of AmericaCourt of Appeals for the Ninth Circuit · 1967
- Mulvania v. CommissionerUnited States Tax Court · 1983
5 more not listed; retrieve them via the Exa API.
3Cited by44 opinions
- William L. King and Darlene E. King v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1988
- Ewing v. CommissionerUnited States Tax Court · 2002
- Gregory W. McKay v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- McKay v. CommissionerUnited States Tax Court · 1987
- Bennion v. CommissionerUnited States Tax Court · 1987
39 more not listed; retrieve them via the Exa API.