Hoj v. Commissioner
United States Tax Court
Jurisdiction -- Petition -- Signing and Verification by Taxpayer. -- The original petition timely filed was not signed by the taxpayers or counsel and was not verified by the taxpayers, but was signed and verified by one who described himself as agent, and the requirements of Rule 7 (h) in regard to verification by someone other than the taxpayers were not complied with in any particular.
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Jurisdiction -- Petition -- Signing and Verification by Taxpayer. -- The original petition timely filed was not signed by the taxpayers or counsel and was not verified by the taxpayers, but was signed and verified by one who described himself as agent, and the requirements of Rule 7 (h) in regard to verification by someone other than the taxpayers were not complied with in any particular. The defects of the petition were called to the attention of the taxpayers by an order to show cause but were not remedied. The proceeding was then dismissed for lack of jurisdiction.
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner determined deficiencies and additions to the tax as follows:
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The notice of deficiency was mailed on February 19, 1953, to “Mr. Soren S. Hoj and Mrs. Caroline Hoj, Husband and Wife, 224 South B Street, Monmouth, Illinois.” A petition was filed on May 19, 1953. That petition was both signed and verified by Charles B. Carpenter, who described himself as “agent or attorney in fact” for the petitioners. An answer was filed. The parties were notified on July 6,1954, that the proceeding would be heard on the merits in Chicago, Illinois, on October…
2Cited by28 opinions
- Carstenson v. CommissionerUnited States Tax Court · 1972
- Kraasch v. CommissionerUnited States Tax Court · 1978
- Abeles v. CommissionerUnited States Tax Court · 1988
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
- Estate of Arnett v. CommissionerUnited States Tax Court · 1958
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