Greenan v. Commissioner

GARRECHT, Circuit Judge.

The question presented here is whether the Tax Court erred in dismissing the proceedings as it related to taxpayer Edith Greenan on the ground that she had not verified the petition and had not made herself a party to the proceeding.

On May 7, 1943, the Commissioner of Internal Revenue had determined a deficiency income tax liability against the taxpayers for the tax years 1935, 1936 and 1938. Within the ninety day period a petition for redetermination of the deficiency was filed in the Tax Court. The petition was signed by counsel and verified by James O. Greenan, one…