Molosh v. Commissioner
United States Tax Court
Petition was received by ordinary mail and filed in the Tax Court on July 23, 1965, which was the 91st day after the notice of deficiency was mailed. The postmark on the covering envelope is illegible but indicates that it was mailed from the General Post Office Station, New York, N.Y., 10001. The postmark has a "PM" notation on it, evidencing the fact that it was mailed sometime after 12 m. on the date of mailing.
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Petition was received by ordinary mail and filed in the Tax Court on July 23, 1965, which was the 91st day after the notice of deficiency was mailed. The postmark on the covering envelope is illegible but indicates that it was mailed from the General Post Office Station, New York, N.Y., 10001. The postmark has a "PM" notation on it, evidencing the fact that it was mailed sometime after 12 m. on the date of mailing. First-class mail which is postmarked July 23 "PM" at the General Post Office Station, New York, N.Y., cannot under any circumstances be delivered in Washington, D.C., on the same…
1Opinion of the Court
OPINION
AkuNdell, Judge:
Respondent mailed a notice of deficiency to petitioners on April 23, 1965. The 90-day period expired on Thursday, July 22, 1965, which was not a holiday in the District of Columbia. The petition was filed with the Court on July 23, 1965, the 91st day.
On September 23, 1965, the respondent filed a motion to dismiss for lack of jurisdiction.
On September 27,1965, this Court “Oedeesd : That this case be dismissed for lack of jurisdiction unless the petitioners on or before October 29, 1965 file written objection to respondent’s motion * * *.”
On October 5, 1965, petitioners…
2Cases cited2 opinions
- Anthony P. Skolski and Kathryne D. Skolski v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1965
- Madison v. CommissionerUnited States Tax Court · 1957
3Cited by24 opinions
- Moffat v. CommissionerUnited States Tax Court · 1966
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Lewy v. CommissionerUnited States Tax Court · 1977
- Rappaport v. CommissionerUnited States Tax Court · 1971
- Vitale v. CommissionerUnited States Tax Court · 1972
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