Helfrich v. Commissioner
United States Tax Court
1. The notice of deficiency was sent by registered mail to petitioner and her former husband at their last known address. Accordingly, the requirements of section 272 (a) and (k), Internal Revenue Code of 1939, are satisfied. 2. Petitioner did not file a joint return with her husband in 1947, nor did she intend to file a joint return with him in that year.
1Opinion of the Court
OPINION.
Bruce, Judge:
The first question for decision is whether the notice of deficiency satisfies the requirements of section 272 (a) and (k), Internal RevenueCode of 1939.
Petitioner contends that the deficiency notice was invalid because it was never received by her. The only address for petitioner and Carl Helfrich shown on the records of the office of the internal revenue agent-in-charge at Springfield, Illinois, was that shown on the return filed in their names for the year 1947. At the time the deficiency notice was issued Alma and Carl were in Mexico. However, the Commissioner had no…
2Cases cited5 opinions
- Brzezinski v. CommissionerUnited States Tax Court · 1954
- Gregory v. United StatesUnited States Court of Claims · 1944
- Bour v. CommissionerUnited States Tax Court · 1954
- Calhoun v. CommissionerUnited States Tax Court · 1954
- McCord v. Granger, Collector of Internal Revenue for 23rd District of PennsylvaniaCourt of Appeals for the Third Circuit · 1952
3Cited by12 opinions
- Levitt v. CommissionerUnited States Tax Court · 1991
- Commissioner of Internal Revenue v. Walter C. Burer and Laverne S. StagesCourt of Appeals for the Fifth Circuit · 1965
- Frank v. CommissionerUnited States Tax Court · 1982
- Helfrich v. CommissionerUnited States Tax Court · 1955
- Herman v. CommissionerUnited States Tax Court · 1979
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