Campbell v. Commissioner
United States Tax Court
R mailed a notice of deficiency to Ps, attached to which were computational sheets relating to another taxpayer. Held, the notice of deficiency is valid.
1Opinion of the Court
OPINION
Fay, Judge:
This matter is before the Court on petitioners’ motion to dismiss for lack of jurisdiction and petitioners’ motion to shift the burden of going forward with the evidence to respondent.1 The issue is whether a notice of deficiency is rendered invalid where the computational pages attached to the notice of deficiency pertained to a taxpayer other than petitioners.
At all relevant times, petitioners resided in Barrington, Illinois.
On April 10, 1986, respondent mailed to petitioners a document containing 9 pages. The first page is a letter designated as Form 5601 (Rev. 4-85)…
2Cases cited4 opinions
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Foster v. Comm'rUnited States Tax Court · 1983
- Kluger v. CommissionerUnited States Tax Court · 1984
- Scar v. CommissionerUnited States Tax Court · 1983
3Cited by52 opinions
- Clapp v. CommissionerCourt of Appeals for the Ninth Circuit · 1989
- Frank C. Pasternak Judith Pasternak (92-1681/1682) Anthony J. Cutaia Diane Cutaia David G. Koehlinger (92-1681) v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1993
- Powers v. CommissionerUnited States Tax Court · 1993
- Thompson v. CommissionerUnited States Tax Court · 2011
- Facq v. Comm'rUnited States Tax Court · 2006
47 more not listed; retrieve them via the Exa API.