Robert D. Gradsky v. Commissioner of Internal Revenue

The above case came on for hearing on the record, the briefs of the parties, and the arguments by counsel for the Commissioner and by petitioner, acting as his own counsel. It appears that a statutory notice of deficiency was mailed to petitioner taxpayer at his correct address by registered mail; that taxpayer’s petition for redetermination of deficiency was not filed within ninety days after the mailing of the notice of deficiency, as provided in Section 272(a) of the Internal Revenue Code, 26 U.S.C.A. § 272.

On the ninetieth day after the mailing of notice of the deficiency, petitioner…