Legal Opinion

Axe v. Commissioner

United States Tax Court

Decided May 9, 1972No. Docket No. 218-72PublishedCited by 47 opinions

On Sept. 28, 1971, respondent mailed to petitioners a statutory notice of deficiency covering Federal income taxes for the years 1968 and 1969. On Dec. 20, 1971, the petitioners, acting through their accountant, prepared an informal petition on the explanation of adjustments page attached to the notice of deficiency and sent it by first-class mail in an envelope addressed to the "Internal Revenue Service, Attention: Tax Court of United States, 200 No. Los Angeles, Calif."

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On Sept. 28, 1971, respondent mailed to petitioners a statutory notice of deficiency covering Federal income taxes for the years 1968 and 1969. On Dec. 20, 1971, the petitioners, acting through their accountant, prepared an informal petition on the explanation of adjustments page attached to the notice of deficiency and sent it by first-class mail in an envelope addressed to the "Internal Revenue Service, Attention: Tax Court of United States, 200 No. Los Angeles, Calif." The petition was received on Dec. 28, 1971, by the Notices Section, Audit Division, Internal Revenue Service, in Los…

1Opinion of the Court

OPINION

Dawson, Judge:

This case is before us on respondent’s motion tq dismiss for lack of jurisdiction.

Petitioners’ legal residence was in Lakewood, Calif., when they filed their petition in this proceeding.

A statutory notice of deficiency was mailed by respondent to the petitioners on September 28,1971, determining income tax deficiencies of $1,513.26 for 1968 and $1,641.06 for 1969. On December 20, 1971, the petitioners, acting through their accountant, prepared an informal petition at the bottom of the explanation of adjustments page attached to the notice of deficiency. This was sent by…

2Cases cited4 opinions

  1. Moffat v. CommissionerUnited States Tax Court · 1966
  2. Rappaport v. CommissionerUnited States Tax Court · 1971
  3. Lurkins v. CommissionerUnited States Tax Court · 1968
  4. Matteson Co. v. CommissionerUnited States Board of Tax Appeals · 1925

3Cited by47 opinions

  1. Cataldo v. CommissionerUnited States Tax Court · 1973
  2. Henry Randolph Consulting v. CommissionerUnited States Tax Court · 1999
  3. Genesis Oil & Gas, Ltd. v. CommissionerUnited States Tax Court · 1989
  4. Estate of Cerrito v. CommissionerUnited States Tax Court · 1980
  5. Weber v. Comm'rUnited States Tax Court · 2004

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