Powers v. Commissioner
United States Board of Tax Appeals
1. Taxpayers who did not sign or verify an original petition filed within the statutory period after deficiency notices were mailed, and who have not shown that the person who purported to sign and verify in their behalf had authority to do so, may not file an amended petition after the statutory period has run.
Read the full summary
1. Taxpayers who did not sign or verify an original petition filed within the statutory period after deficiency notices were mailed, and who have not shown that the person who purported to sign and verify in their behalf had authority to do so, may not file an amended petition after the statutory period has run. Respondent's motion to dismiss as to such taxpayers, for want of jurisdiction, is granted. 2. Respondent's motion to dismiss as to a person joining in a petition, and such person failing to show that a deficiency notice has been mailed to him, is granted. 3. A single petition in which…
1Opinion of the Court
OPINION.
Arttndell :
This proceeding came on for hearing on respondent’s motion to dismiss for want of jurisdiction as to certain of the persons set out above as petitioners. The pertinent facts are as follows:
On December 3, 1929, respondent mailed notices of deficiency to the following ten persons:
Percy N. Powers
Mary Jessie Powell, Administratrix,
Estate of Mary I. Ball
Jesse W. Powers, 2nd.
Harry L. Powers
National Iron Bank, Executor,
Estate of Charles H. Powers
Elsie B. Fowler
Isabelle M. Cochrane
M. Frances Francis
Jesse W. Powers, 3rd.
Lillian A. P. Esmond
Within 60 days thereafter, to wit, on…
2Cases cited2 opinions
- Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920
- Russell v. United StatesSupreme Court of the United States · 1929
3Cited by14 opinions
- Brooks v. CommissionerUnited States Tax Court · 1975
- Fletcher Plastics, Inc. v. CommissionerUnited States Tax Court · 1975
- Hoffman v. CommissionerUnited States Tax Court · 1975
- Du Puy v. CommissionerUnited States Tax Court · 1967
- Eiges v. CommissionerUnited States Tax Court · 1993
9 more not listed; retrieve them via the Exa API.