Scruggs v. Commissioner
United States Board of Tax Appeals
Where a notice of deficiency is erroneously addressed to a certain individual as administrator of the estate of the deceased taxpayer, which notice clearly shows that the proposed deficiency is asserted against the estate of the deceased taxpayer for the taxable year, and a timely petition for redetermination of the tax is filed with the Board by the duly appointed administratrix of the decedent's estate, containing no allegation with respect to the misnomer in the…
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Where a notice of deficiency is erroneously addressed to a certain individual as administrator of the estate of the deceased taxpayer, which notice clearly shows that the proposed deficiency is asserted against the estate of the deceased taxpayer for the taxable year, and a timely petition for redetermination of the tax is filed with the Board by the duly appointed administratrix of the decedent's estate, containing no allegation with respect to the misnomer in the deficiency notice, it is held that the petitioner has not been misled by the method of addressing and, by appearing before the…
1Opinion of the Court
OPINION.
Matthews :
On March 16, 1931, J. D. Scruggs of Madison, Florida, filed his income tax return for the year 1930 with the collector of internal revenue for the District of Florida. On October 24, 1931, J. D. Scruggs died intestate. His widow, Corinne Porter Scruggs, was appointed administratrix of his estate and letters of administration were duly granted to her under date of November 2, 1931, by the County Judge of Madison County, Florida.
On May 30,1932, Corinne Porter Scruggs, as administratrix of the estate of J, D, Scruggs, deceased, executed a power of attorney *1103authorizing J. M.…
2Cases cited9 opinions
- Kay Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Bankers Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Eisendrath v. CommissionerUnited States Board of Tax Appeals · 1933
- Howell v. CommissionerUnited States Board of Tax Appeals · 1930
- New York Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1930
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3Cited by5 opinions
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