Degill Corp. v. Commissioner
United States Tax Court
Petitioner is a Pennsylvania corporation with its registered office in Philadelphia. Its entire business operations were conducted in the South Pacific where its officers and employees, most of its shareholders, its books and records, and its business equipment were located. On Dec. 12, 1972, a notice of deficiency was sent to petitioner by certified mail at the address of its registered office in Philadelphia.
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Petitioner is a Pennsylvania corporation with its registered office in Philadelphia. Its entire business operations were conducted in the South Pacific where its officers and employees, most of its shareholders, its books and records, and its business equipment were located. On Dec. 12, 1972, a notice of deficiency was sent to petitioner by certified mail at the address of its registered office in Philadelphia. On the same day a conformed copy of the notice of deficiency was mailed to petitioner's Singapore address. On Mar. 10, 1973, petitioner sent its petition by registered mail from the…
1Opinion of the Court
Dawson, Judge:
Respondent determined the following Federal income tax deficiencies and additions to tax against the petitioner:
Additions to tax Tax year ended Deficiency - Sec. 6053(b) 1 . Sec. 6651(a)
Apr. 30,1967. $200,360.13 $122,827.91 ($5,198.00)
Apr. 30,1968. 44,777.20 32,343.40 .
Apr. 30,1969. 22,678.74 . 11,339.37 .
On May 22,1973, respondent filed a motion to dismiss this case for lack of jurisdiction on the ground that the petition was not timely filed within 90 days after the notice of deficiency was mailed. On November 23,1973, the petitioner filed its Objections to respondent’s…
2Cases cited11 opinions
- Lifter v. CommissionerUnited States Tax Court · 1973
- McCormick v. CommissionerUnited States Tax Court · 1970
- Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
- Berger v. CommissionerCourt of Appeals for the Third Circuit · 1968
- Berger v. CommissionerUnited States Tax Court · 1967
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3Cited by20 opinions
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