Legal Opinion

Hoffenberg v. Commissioner

United States Tax Court

Decided December 27, 1989No. Docket No. 31549-87UnpublishedCited by 4 opinions

On the date the notice of deficiency was mailed P's "last known address" was 34 Paerdegat 10 Street, Brooklyn, N.Y. 11236. On October 10, 1985, R sent his notice of deficiency by certified mail to P addressed as follows: "Mr. Steven Hoffenberg, c/o Jessie Vogel, Esq., 34 Paerdegat 10 Street, Brooklyn, N.Y. 11236." The petition was filed on September 18, 1987, and the envelope in which it was contained bears a clearly legible U.S. postmark date of "Sep. 16, 1987." P claims…

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On the date the notice of deficiency was mailed P's "last known address" was 34 Paerdegat 10 Street, Brooklyn, N.Y. 11236. On October 10, 1985, R sent his notice of deficiency by certified mail to P addressed as follows: "Mr. Steven Hoffenberg, c/o Jessie Vogel, Esq., 34 Paerdegat 10 Street, Brooklyn, N.Y. 11236." The petition was filed on September 18, 1987, and the envelope in which it was contained bears a clearly legible U.S. postmark date of "Sep. 16, 1987." P claims that the notice is defective and, thus, invalid because it was improperly addressed and not received until 1987. R…

1Opinion of the Court

STEVEN HOFFENBERG, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Hoffenberg v. Commissioner

Docket No. 31549-87

United States Tax Court

T.C. Memo 1989-676; 1989 Tax Ct. Memo LEXIS 676; 58 T.C.M. (CCH) 1038; T.C.M. (RIA) 89676;

December 27, 1989

On the date the notice of deficiency was mailed P's "last known address" was 34 Paerdegat 10 Street, Brooklyn, N.Y. 11236. On October 10, 1985, R sent his notice of deficiency by certified mail to P addressed as follows: "Mr. Steven Hoffenberg, c/o Jessie Vogel, Esq., 34 Paerdegat 10 Street, Brooklyn, N.Y. 11236." The petition was filed on…

2Cases cited18 opinions

  1. United States v. Edward J. AhrensCourt of Appeals for the Eighth Circuit · 1976
  2. Olsen v. HelveringCourt of Appeals for the Second Circuit · 1937
  3. Cataldo v. CommissionerUnited States Tax Court · 1973
  4. Mulvania v. CommissionerUnited States Tax Court · 1983
  5. Keeton v. CommissionerUnited States Tax Court · 1980

13 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Eiges v. CommissionerUnited States Tax Court · 1993
  2. Davis v. CommissionerUnited States Tax Court · 1990
  3. Eiges v. CommissionerUnited States Tax Court · 1993
  4. Watkins v. CommissionerUnited States Tax Court · 1992

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