Williams v. Commissioner
United States Tax Court
1. Where the communication relied on by petitioner as the statutory deficiency notice is not shown to have been sent to him by registered mail, the Tax Court is without jurisdiction of a proceeding grounded thereon. 2. The jurisdiction of the Tax Court does not include matters relating to the enforcement of warrants for distraint. Accordingly, a motion for the entry of an order to stay the enforcement of such a warrant will be dismissed for lack of jurisdiction.
1Opinion of the Court
Roger J. Williams, Petitioner, v. Commissioner of Internal Revenue, Respondent
Williams v. Commissioner
Docket No. 22377
United States Tax Court
13 T.C. 257; 1949 U.S. Tax Ct. LEXIS 102;
August 24, 1949, Promulgated
1. Where the communication relied on by petitioner as the statutory deficiency notice is not shown to have been sent to him by registered mail, the Tax Court is without jurisdiction of a proceeding grounded thereon.
2. The jurisdiction of the Tax Court does not include matters relating to the enforcement of warrants for distraint. Accordingly, a motion for the entry of an order to stay…
2Cases cited3 opinions
- Midtown Catering Co. v. CommissionerUnited States Tax Court · 1949
- John A. Gebelein, Inc. v. CommissionerUnited States Board of Tax Appeals · 1938
- Williams v. CommissionerUnited States Tax Court · 1949