Snow v. Comm'r
United States Tax Court
In 1993 R mailed notices of deficiency regarding Ps' 1987 and 1990 tax years. In 1995 Ps filed petitions with the Court. Ps moved to dismiss for lack of jurisdiction alleging that the notices of deficiency had not been mailed to Ps' last known address and were therefore invalid. R also moved to dismiss for lack of jurisdiction because the petitions were untimely. These cases were assigned to a Special Trial Judge who wrote an initial report granting Ps' motions to dismiss.
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In 1993 R mailed notices of deficiency regarding Ps' 1987 and 1990 tax years. In 1995 Ps filed petitions with the Court. Ps moved to dismiss for lack of jurisdiction alleging that the notices of deficiency had not been mailed to Ps' last known address and were therefore invalid. R also moved to dismiss for lack of jurisdiction because the petitions were untimely. These cases were assigned to a Special Trial Judge who wrote an initial report granting Ps' motions to dismiss. Because of the amounts in issue, the decisions in these cases were required by statute to be made by a regular Judge.…
1Opinion of the Court
OPINION
Ruwe, Judge:
The matter before us concerns petitioners’ motions for leave to file motions to vacate orders of dismissal. 1 The motions were filed on July 3, 2013. The orders of dismissal that petitioners’ motions seek to vacate were entered on October 15, 1996, pursuant to our opinion in Snow v. Commissioner, T.C. Memo. 1996-457.
Background
The petitions in these cases were filed in 1995 regarding notices of deficiency for the taxable years 1987 and 1990. The notices of deficiency had been mailed in May 1993.
Shortly after the petitions were filed, the parties each moved to dismiss for…
2Cases cited32 opinions
- United States v. DalmSupreme Court of the United States · 1990
- Monge v. CommissionerUnited States Tax Court · 1989
- Commissioner v. McCoySupreme Court of the United States · 1987
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Josephine C. Toscano AKA Josephine C. Zelasko v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
27 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Douglas P. Snow & Deborah J. Snow v. CommissionerUnited States Tax Court · 2014
- Ronald E. Byers v. CommissionerUnited States Tax Court · 2019
- Snow v. Comm'rUnited States Tax Court · 2014