Legal Opinion

Bruder v. Commissioner

United States Tax Court

Decided July 11, 1989No. Docket No. 8636-88UnpublishedCited by 1 opinion

After receiving an extension of time within which to file, petitioners deposited their 1983 Federal income tax return in the United States mail sometime after April 19, 1984. Their return was never received. Held: Petitioners did not file a Federal income tax return for 1983, and respondent's notice of deficiency is not barred by the statute of limitations.

1Opinion of the Court

ALAN F. BRUDER AND MARY J. BRUDER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bruder v. Commissioner

Docket No. 8636-88

United States Tax Court

T.C. Memo 1989-328; 1989 Tax Ct. Memo LEXIS 330; 57 T.C.M. (CCH) 873; T.C.M. (RIA) 89328;

July 11, 1989

After receiving an extension of time within which to file, petitioners deposited their 1983 Federal income tax return in the United States mail sometime after April 19, 1984. Their return was never received. Held: Petitioners did not file a Federal income tax return for 1983, and respondent's notice of deficiency is not barred by the…

2Cited by1 opinion

  1. Nick L. Surowka and Christine L. Surowka v. United StatesCourt of Appeals for the Sixth Circuit · 1990

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