Legal Opinion

Cataldo v. Commissioner

United States Tax Court

Decided June 28, 1973No. Docket No. 6506-72Published

Held: 1. The alleged failure of the respondent to provide the petitioners a hearing before the Appellate Division did not render the notice of deficiency invalid. 2. The respondent has proved by competent evidence the date of the mailing of the notice of deficiency.

1Opinion of the Court

Anthony B. Cataldo and Ada W. Cataldo, Petitioners v. Commissioner of Internal Revenue, Respondent

Cataldo v. Commissioner

Docket No. 6506-72

United States Tax Court

60 T.C. 522; 1973 U.S. Tax Ct. LEXIS 99; 60 T.C. No. 57;

June 28, 1973, Filed

Held: 1. The alleged failure of the respondent to provide the petitioners a hearing before the Appellate Division did not render the notice of deficiency invalid.

2. The respondent has proved by competent evidence the date of the mailing of the notice of deficiency.

Anthony B. Cataldo, pro se.

H. Stephen Kesselman, for the respondent.

Simpson, Judge.

SIMPSON

OPINION

2Cases cited17 opinions

  1. Cataldo v. CommissionerUnited States Tax Court · 1973
  2. Thelma Rosenberg v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  3. Flynn v. CommissionerUnited States Tax Court · 1963
  4. Houghton v. CommissionerUnited States Tax Court · 1967
  5. Axe v. CommissionerUnited States Tax Court · 1972

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