Holt v. Commissioner
United States Tax Court
Rules 34(a), 34(b)(7), 41(a), and 60(a), Tax Court Rules of Practice and Procedure. -- Petitioners filed joint Federal income tax returns for 1971, 1972, and 1973 and received a joint statutory notice of deficiency dated Oct. 17, 1975. An uncaptioned letter mailed on Jan. 13, 1976, and signed only by the husband, was received by the Court on Jan. 15, 1976, and was treated and filed by the Court as an imperfect petition.
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Rules 34(a), 34(b)(7), 41(a), and 60(a), Tax Court Rules of Practice and Procedure. -- Petitioners filed joint Federal income tax returns for 1971, 1972, and 1973 and received a joint statutory notice of deficiency dated Oct. 17, 1975. An uncaptioned letter mailed on Jan. 13, 1976, and signed only by the husband, was received by the Court on Jan. 15, 1976, and was treated and filed by the Court as an imperfect petition. On Mar. 17, 1976, the Court received a petition (filed as an amended petition) captioned in the names of both petitioners and signed by both. On June 30, 1976, respondent…
1Opinion of the Court
Ernest B. Holt and Lessie L. Holt, Petitioners v. Commissioner of Internal Revenue, Respondent
Holt v. Commissioner
Docket No. 465-76
United States Tax Court
67 T.C. 829; 1977 U.S. Tax Ct. LEXIS 150;
February 24, 1977, Filed
Rules 34(a), 34(b)(7), 41(a), and 60(a), Tax Court Rules of Practice and Procedure. -- Petitioners filed joint Federal income tax returns for 1971, 1972, and 1973 and received a joint statutory notice of deficiency dated Oct. 17, 1975. An uncaptioned letter mailed on Jan. 13, 1976, and signed only by the husband, was received by the Court on Jan. 15, 1976, and was treated and…
Also in this document: Concurrence · Scott; Concurrence · Wilbur; Dissent.
2Cases cited18 opinions
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Fishman v. CommissionerUnited States Tax Court · 1969
- Brooks v. CommissionerUnited States Tax Court · 1975
- Irving and Helen Fishman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1970
- William I. Tenzer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
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