Ward v. Commissioner
United States Tax Court
Ps filed a 1981 return in April 1982 reflecting a Houston, Texas, address. P, Joan Ward, died after the return was filed. On Oct. 31, 1986, P, Gerald Ward (hereinafter P), moved to Kingwood, Texas. On Nov. 6, 1986, P advised the Austin, Texas, service center of his change of address. On Nov. 18, 1986, the service center acknowledged receipt of P's letter. On Nov. 20, 1986, the Houston district IRS office issued a notice of deficiency to Ps at the Houston address.
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Ps filed a 1981 return in April 1982 reflecting a Houston, Texas, address. P, Joan Ward, died after the return was filed. On Oct. 31, 1986, P, Gerald Ward (hereinafter P), moved to Kingwood, Texas. On Nov. 6, 1986, P advised the Austin, Texas, service center of his change of address. On Nov. 18, 1986, the service center acknowledged receipt of P's letter. On Nov. 20, 1986, the Houston district IRS office issued a notice of deficiency to Ps at the Houston address. Ps' petition was filed on May 25, 1988. On the same date, Ps filed a motion to dismiss for lack of jurisdiction on the ground that…
1Opinion of the Court
OPINION
Fay, Judge:
This case was heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A of the Code.1 The Court agrees with and adopts the Special Trial Judge’s opinion, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Special Trial Judge:
This case came before the Court on respondent’s motion to vacate the Court’s order of dismissal for lack of jurisdiction. If respondent’s motion to vacate is to be granted, we must then consider petitioners’ motion to dismiss for lack of jurisdiction filed May 25, 1988, and respondent’s cross-motion to…
2Cases cited18 opinions
- Societe Internationale Pour Participations Industrielles Et Commerciales, S. A. v. RogersSupreme Court of the United States · 1958
- Frieling v. CommissionerUnited States Tax Court · 1983
- Pyo v. CommissionerUnited States Tax Court · 1984
- Abeles v. CommissionerUnited States Tax Court · 1988
- Rechtzigel v. CommissionerUnited States Tax Court · 1982
13 more not listed; retrieve them via the Exa API.
3Cited by18 opinions
- Gerald D. Ward and Joan Ward (Deceased) v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Snow v. Comm'rUnited States Tax Court · 2014
- Lee v. Comm'rUnited States Tax Court · 2011
- Lueck v. CommissionerUnited States Tax Court · 1990
- Hunter v. Comm'rUnited States Tax Court · 2004
13 more not listed; retrieve them via the Exa API.