Legal Opinion
Patmon and Young Professional Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided May 23, 1995No. 93-1956PublishedCited by 24 opinions
1Opinion of the Court
SILER, Circuit Judge.
Patmon and Young Professional Corporation (“P & Y”) appeals the United States Tax Court’s order dismissing its petition seeking redetermination of tax deficiencies assessed against P & Y. For the reasons stated herein, we hold that the Tax Court did not err in dismissing P & Y’s petition for redetermination based upon lack of jurisdiction on the ground that it was untimely filed.
I
On March 3, 1989, the Internal Revenue Service (“IRS”) mailed, by certified mail, a statutory notice of deficiency addressed to P & Y at Post Office Box 315189, Detroit, Michigan 48231. It also…
2Cases cited10 opinions
- Anderson v. City of Bessemer CitySupreme Court of the United States · 1985
- Meyer Harris Cohen, AKA Michael 'Mickey' Cohen v. United StatesCourt of Appeals for the Ninth Circuit · 1962
- Floyd R. Clodfelter and Enna L. Clodfelter v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Commissioner of Internal Revenue v. StewartCourt of Appeals for the Sixth Circuit · 1951
- Joseph Delman and Jeanette Delman v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
5 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Sego v. CommissionerUnited States Tax Court · 2000
- Reliance Insurance v. Mast Construction Co.Court of Appeals for the Tenth Circuit · 1998
- Terrell v. CommissionerCourt of Appeals for the Fifth Circuit · 2010
- Ellen v. Erhard v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
- M-DBoard of Immigration Appeals · 2002
19 more not listed; retrieve them via the Exa API.