Legal Opinion
George K. Drake and Charlene C. Drake v. Commissioner of Internal Revenue Service
Court of Appeals for the Fifth Circuit
Decided June 24, 1977No. 75-3473PublishedCited by 40 opinions
1Opinion of the Court
JAMES C. HILL, Circuit Judge:
This is a tax case in which the facts are undisputed and the question presented is quite straightforward. The sole issue is whether taxpayers’ petition for redetermination filed in the tax court was timely under section 7502 of the Internal Revenue Code of 1954 (I.R.C.). The tax court concluded that the filing was untimely and dismissed the petition. We affirm.
On February 5,1975, notices of deficiency were mailed to taxpayers, George K. and Charlene C. Drake, for their tax years 1966-1969. 1 At 6:00 p. m. on the ninetieth day following the mailing of the notices—…
2Cases cited5 opinions
- Phillips v. CommissionerSupreme Court of the United States · 1931
- C. Louis Wood and Hallie D. Wood v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Albert G. Rich v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Thomas and Delilah Boccuto v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1960
3Cited by40 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Castillo, Ex Parte Mario AmaroCourt of Criminal Appeals of Texas · 2012
- Brian Miller v. United StatesCourt of Appeals for the Sixth Circuit · 1986
- David Deutsch v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1979
- James E. Shipley and Patricia B. Shipley v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1978
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