Du Pasquier v. Commissioner
United States Tax Court
Jurisdiction -- 90 or 150 Days for Filing -- Person Outside the United States -- Sec. 6213 (a), 1954 Code. -- If the person to whom the notice of deficiency is addressed is outside the United States at the time the notice is mailed and there dies, the 150-day period applies.
1Opinion of the Court
OPINION.
Tietjens, Judge:
The notices of deficiency in both of the cases before ns are dated June 22,1962. Separate petitions were filed in each of the causes on November 8,1962.
The notice of deficiency filed with the petition in Docket No. 4327-62 was addressed as follows:
Mr. Pierre due Pasquier
c/o Ellsworth C. Alvord
World Center Building
Washington 6, D.C.
And the notice of deficiency filed with the petition in Docket No. 4328-62 was addressed as follows:
Mrs. Marcella due Pasquier
c/o Ellsworth C. Alvord
World Center Building
Washington 6, D.C.
Separate duplicate originals of these notices of…
2Cases cited3 opinions
- Mindell v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1952
- Hamilton v. CommissionerUnited States Tax Court · 1949
- Bowyer v. CommissionerUnited States Tax Court · 1960
3Cited by5 opinions
- Lewy v. CommissionerUnited States Tax Court · 1977
- Mianus Realty Co. v. CommissionerUnited States Tax Court · 1968
- Du Pasquier v. CommissionerUnited States Tax Court · 1963
- Lewy v. CommissionerUnited States Tax Court · 1977
- Mianus Realty Co. v. CommissionerUnited States Tax Court · 1968