Mason v. Commissioner of Internal Revenue (Two Cases)

HUTCHESON, Chief Judge.

These appeals, consolidated for briefing and argument, are taken from orders of the Tax Court which granted, without opinion, the commissioner’s motions 1 to dismiss, for want of jurisdiction, petitions 2 taxpayers had filed for a rede- termination of the deficiencies, set forth in his jeopardy assessments of March 14, 1952, and mailed to taxpayers’ attorney May 26, 1952.

As the taxpayers state the question for decision, it is whether the Commissioner of Internal Revenue can, by the simple expedient of (1) issuing jeopardy assessments and (b) failing to comply with the…