Hess v. Commissioner
United States Tax Court
Ps' claim they mailed the petitions to the Tax Court by certified mail return receipt requested. Having lost the originals, they produced copies of timely U.S. postmarked Receipts For Certified Mail (U.S. Postal Service Forms 3800). The envelopes in which the petitions were received by the Court bear insufficient postage for certified mail and they bear untimely U.S. postmarks. Ps did not produce either the originals or copies of the Domestic Return Receipts (U.S.
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Ps' claim they mailed the petitions to the Tax Court by certified mail return receipt requested. Having lost the originals, they produced copies of timely U.S. postmarked Receipts For Certified Mail (U.S. Postal Service Forms 3800). The envelopes in which the petitions were received by the Court bear insufficient postage for certified mail and they bear untimely U.S. postmarks. Ps did not produce either the originals or copies of the Domestic Return Receipts (U.S. Postal Service Forms 3811). No certified mail sticker or Domestic Return Receipt has ever been affixed to either envelope. The…
1Opinion of the Court
GRETCHEN HESS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent; HENRY BARTENBACH AND FREDDA BARTENBACH, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hess v. Commissioner
Docket Nos. 22332-85, 22334-85
United States Tax Court
T.C. Memo 1989-412; 1989 Tax Ct. Memo LEXIS 410; 57 T.C.M. (CCH) 1224; T.C.M. (RIA) 89412;
August 10, 1989
Ps' claim they mailed the petitions to the Tax Court by certified mail return receipt requested. Having lost the originals, they produced copies of timely U.S. postmarked Receipts For Certified Mail (U.S. Postal Service Forms 3800). The envelopes…
2Cases cited14 opinions
- Emmons v. CommissionerUnited States Tax Court · 1989
- Moffat v. CommissionerUnited States Tax Court · 1966
- C. Louis Wood and Hallie D. Wood v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1964
- Sylvan v. CommissionerUnited States Tax Court · 1975
- Wood v. CommissionerUnited States Tax Court · 1964
9 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Eiges v. CommissionerUnited States Tax Court · 1993
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