Bendheim v. Commissioner of Internal Revenue

MEDINA, Circuit Judge.

The taxpayer’s petition for review presents a narrow procedural question affecting the jurisdiction of the Tax Court.

Having filed an income tax return indicating no tax liability whatever for 1943, the taxpayer was notified on March 17, 1947, by the internal revenue agent in charge for the Upper New York Division, that a deficiency in the amount of $17,582.87 was being proposed. Within the thirty-day period following the receipt of the letter proposing this deficiency, the taxpayer filed a protest, and certain conferences and the submission of supplementary material…