Legal Opinion

Zaun v. Commissioner

United States Tax Court

Decided June 3, 1974No. Docket Nos. 1941-71, 1942-71Published

Timely deficiency notices were mailed to petitioners and they filed their petitions before the expiration of the 90-day period specified in sec. 6213(a), I.R.C. 1954. They received oral notice of the mailings prior to the expiration of such period but did not receive the written notices until after such expiration, which nevertheless was within the applicable period for assessment.

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Timely deficiency notices were mailed to petitioners and they filed their petitions before the expiration of the 90-day period specified in sec. 6213(a), I.R.C. 1954. They received oral notice of the mailings prior to the expiration of such period but did not receive the written notices until after such expiration, which nevertheless was within the applicable period for assessment. Held, despite some confusion as to petitioners' "last known address," the timely filing of the petitions was sufficient to confer jurisdiction on the Court and petitioners' motions to dismiss for lack of…

1Opinion of the Court

Richard A. Zaun, Petitioner v. Commissioner of Internal Revenue, Respondent; Lois Jean Zaun, Petitioner v. Commissioner of Internal Revenue, Respondent

Zaun v. Commissioner

Docket Nos. 1941-71, 1942-71

United States Tax Court

62 T.C. 278; 1974 U.S. Tax Ct. LEXIS 99; 62 T.C. No. 33;

June 3, 1974, Filed

Timely deficiency notices were mailed to petitioners and they filed their petitions before the expiration of the 90-day period specified in sec. 6213(a), I.R.C. 1954. They received oral notice of the mailings prior to the expiration of such period but did not receive the written notices until after…

2Cases cited5 opinions

  1. Lifter v. CommissionerUnited States Tax Court · 1973
  2. Zaun v. CommissionerUnited States Tax Court · 1974
  3. Birnie v. CommissionerUnited States Tax Court · 1951
  4. Teitelbaum v. CommissionerUnited States Tax Court · 1963
  5. Cox v. CommissionerUnited States Tax Court · 1970

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