Legal Opinion

O'Neil v. Commissioner

United States Tax Court

Decided April 15, 1976No. Docket No. 5594-75Published

Rules 40 and 41, Tax Court Rules of Practice and Procedure. -- The Commissioner determined deficiencies in P's tax for the years 1968-71 and sent P one notice of deficiency.

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Rules 40 and 41, Tax Court Rules of Practice and Procedure. -- The Commissioner determined deficiencies in P's tax for the years 1968-71 and sent P one notice of deficiency. P timely filed a petition with this Court attaching such notice but contesting only the Commissioner's determinations for 1968-70. After the 90-day period had expired, P filed an amended petition contesting the Commissioner's determination for 1971. Held, since P's timely petition did not clearly indicate that he was contesting the determination for 1971, the Commissioner's determination for that year is not at issue.

1Opinion of the Court

Richard A. O'Neil, Petitioner v. Commissioner of Internal Revenue, Respondent

O'Neil v. Commissioner

Docket No. 5594-75

United States Tax Court

66 T.C. 105; 1976 U.S. Tax Ct. LEXIS 126;

April 15, 1976, Filed

Rules 40 and 41, Tax Court Rules of Practice and Procedure. -- The Commissioner determined deficiencies in P's tax for the years 1968-71 and sent P one notice of deficiency. P timely filed a petition with this Court attaching such notice but contesting only the Commissioner's determinations for 1968-70. After the 90-day period had expired, P filed an amended petition contesting the…

2Cases cited14 opinions

  1. Commissioner v. SunnenSupreme Court of the United States · 1948
  2. Brooks v. CommissionerUnited States Tax Court · 1975
  3. Carstenson v. CommissionerUnited States Tax Court · 1972
  4. O'Neil v. CommissionerUnited States Tax Court · 1976
  5. Joannou v. CommissionerUnited States Tax Court · 1960

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