Legal Opinion

Dudley v. Comm'r

United States Tax Court

Decided August 14, 1957No. Docket No. 66978Published

Jurisdiction -- Notice of Deficiency -- Department of Finance of Virgin Islands. -- There is no showing that the Head of the Tax Division of the Department of Finance of the Government of the Virgin Islands was authorized as a delegate of the Secretary under section 6212 of the I. R. C. 1954 to notify the petitioner of a deficiency in income tax and a notice from such person does not give this Court jurisdiction.

1Opinion of the Court

George H. T. Dudley, Petitioner, v. Commissioner of Internal Revenue, Respondent

Dudley v. Comm'r

Docket No. 66978

United States Tax Court

28 T.C. 992; 1957 U.S. Tax Ct. LEXIS 118; 3 V.I. 471;

August 14, 1957, Filed

Decision will be entered dismissing the proceeding for lack of jurisdiction.

Jurisdiction -- Notice of Deficiency -- Department of Finance of Virgin Islands. -- There is no showing that the Head of the Tax Division of the Department of Finance of the Government of the Virgin Islands was authorized as a delegate of the Secretary under section 6212 of the I. R. C. 1954 to notify the…

2Cases cited2 opinions

  1. Dudley v. Comm'rUnited States Tax Court · 1957
  2. Fairchild v. CommissionerUnited States Tax Court · 1955

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