Legal Opinion
Charles R. Sicker v. Commissioner of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided May 1, 1987No. 86-5498PublishedCited by 14 opinions
Non-Argument Calendar.
1Opinion of the Court
HILL, Circuit Judge:
This appeal involves the timeliness of a taxpayer’s filing of a petition for redeter-mination of deficiency. On July 29, 1985, the Internal Revenue Service mailed appellant Charles Sicker a notice of deficiency. See 26 U.S.C. § 6212(a) (1982). This notice was mailed to Rt. 1, Box 1635, O’Keecho-bee, FL 33472. Appellant’s last known address, however, was Rt. 1, Box 1635, O’Keechobee, FL 33472.
Before the Tax Court, 1 appellant maintained that the notice of deficiency was sent to his ex-wife and he did not learn of it until October 24 — 87 days after the notice was mailed.…
2Cases cited3 opinions
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Henry G. Pugsley v. Commissioner of Internal Revenue, Joseph T. Rezzonico v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Richard L. Mulvania v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1985
3Cited by14 opinions
- Ewing v. CommissionerUnited States Tax Court · 2002
- Kuykendall v. Comm'rUnited States Tax Court · 2007
- Harry Holof and Norma Holof v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1989
- Pollock v. Comm'rUnited States Tax Court · 2009
- William B. Scheidt and Wanda C. Scheidt v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1992
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