Cowan v. Commissioner
United States Tax Court
Held: 1. The fact that one of petitioners, Jules Cowan, was in Tijuana, Mexico, from 9 a.m. until 7:30 p.m. on the day the notice of deficiency was mailed to him does not cause him to have 150 days from the date of the mailing of the notice of deficiency within which to file a petition with this Court. 2. The fact that two unidentified employees of the Internal Revenue Service told petitioner Jules Cowan that he had until Aug. 6, 1969, to file a petition with this Court…
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Held: 1. The fact that one of petitioners, Jules Cowan, was in Tijuana, Mexico, from 9 a.m. until 7:30 p.m. on the day the notice of deficiency was mailed to him does not cause him to have 150 days from the date of the mailing of the notice of deficiency within which to file a petition with this Court. 2. The fact that two unidentified employees of the Internal Revenue Service told petitioner Jules Cowan that he had until Aug. 6, 1969, to file a petition with this Court seeking a redetermination of taxes determined in a notice of deficiency mailed to him on May 7, 1969, does not in effect…
1Opinion of the Court
OPINION
Respondent takes the position that under the provisions of section 6213(a)2 petitioners’ petition to this Court was required to be filed within 90 days after the notice of deficiency was mailed to each of them. Respondent takes the further position that any statements made to Jules Cowan by unidentified employees of the Internal Revenue Service would not extend the time allowed by statute for filing a petition with tMs Court.
Petitioner contends that he had 150 days from May 7, 1969, to file a petition with this Court contesting the deficiencies determined in the notice mailed to him on…
2Cases cited6 opinions
- Arkansas Motor Coaches, Limited, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
- William I. Tenzer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- Arlington Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Estate of Krueger v. CommissionerUnited States Tax Court · 1960
- Mindell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
1 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Looper v. CommissionerUnited States Tax Court · 1980
- Lewy v. CommissionerUnited States Tax Court · 1977
- Camous v. CommissionerUnited States Tax Court · 1977
- Malekzad v. CommissionerUnited States Tax Court · 1981
- Levy v. CommissionerUnited States Tax Court · 1981
16 more not listed; retrieve them via the Exa API.